Effective and last updated September 7, 2023
If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Financial Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
- PERSONAL DATA WE COLLECT
- HOW WE USE YOUR PERSONAL DATA
- HOW WE SHARE YOUR PERSONAL DATA
- THIRD PARTY SERVICES
- OPT-OUT PREFERENCE SIGNALS
- THIRD PARTY LINKS
- CHILDREN'S PRIVACY
- NOTICE TO CALIFORNIA RESIDENTS
- MEDIA INFORMATION
- HOW TO CONTACT US
1. PERSONAL DATA WE COLLECT
We collect personal data from you through your use of the Sites and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. We collect the following types of personal data:
Personal Data You Provide
We collect the following personal data that you voluntarily provide to us in using our Sites and Services:
- Get a Quote, Inquire or Request Information. If you request to receive a quote, inquire on one of our Sites, or request information on our products and services, we will collect your first and last name, email address, telephone number, and other general information to customize the service offerings, such as your income range and estimated sale price of the home.
- Apply for a Loan. If you apply for a loan, we will collect your first and last name, email address, telephone number, postal address, Social Security number, professional or employment-related information, commercial and financial information such as your loan details and payment history, and information about your preferences and needs to customize your service offerings and user experience. We may use a third party to collect some of this information on our behalf. See the section titled, "THIRD PARTY PROCESSORS" below.
- Contact Us or an Agent. If you request to speak with an agent through our online form, we will collect your first and last name, email address, and telephone number. We will also collect your email address and any information you choose to provide to us when you contact us by email.
- Register for an Account for Online or Mobile Applications. If you register for an online account through our online or mobile applications to track your loan application and/or manage your loan, we will collect information such as your last name, username and password, loan number, Social Security number, date of birth, email address, and security questions and answers. We also will collect a device identifier and location to provide additional security to protect your account. If you use your online account to make a mortgage payment or sign up for automatic payments, we will also collect your bank account information and other information required to make a payment. We use Black Knight, Inc. to host our online and mobile applications that enable you to manage your loan online and process this information on our behalf. Please see Black Knight, Inc.'s privacy notice here. Additionally, if you use a third party website, such as Google or Facebook, to register or log into our online or mobile applications, we will have access to information that is made available by those websites.
- Apply to Join Our Team. If you apply for a job opening or to become a loan officer, we will collect information such as your first and last name, email address, telephone number and home address.
To review or request changes to any of your personal data, please contact us as described in the "HOW TO CONTACT US" section below.
Personal Data as You Navigate Our Sites
- Usage Information. For example, the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
- Device Information. For example, hardware model, operating system, application version number, and browser.
- Mobile Device Information. Aggregated information about whether the Sites are accessed via a mobile device or tablet, the device type, and the carrier.
- Location Information. Location information from visitors to the Sites on a city-regional basis.
Personal Data We Collect About You from Other Sources
In some cases, we may receive personal data about you from other sources, such as advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers.
2. HOW WE USE YOUR PERSONAL DATA
We use the personal data we collect to provide the Services to you, to improve our Sites and Services, and to protect our legal rights. In addition, depending on how you interact with our Sites and Services, we may use the personal data we collect to:
- Process your account registration;
- Process your loan application;
- Review your job application;
- Provide member account disclosures and notifications for certain loan activity;
- Respond to your requests, feedback, and inquiries;
- Contact you regarding our products and services that we feel may be of interest to you – to unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails;
- Communicate with you about our Sites or Services or to inform you of any changes to our Sites or Services;
- Provide support;
- Maintain and improve our Sites and Services;
- Protect the security and integrity of our Sites and Services;
- Defend our legal rights and the rights of others;
- Fulfill any other purposes for which you provide it, or any other purpose we deem necessary or appropriate;
- Efficiently maintain our business; and
- Comply with applicable law.
3. HOW WE SHARE YOUR PERSONAL DATA
We may share the personal data that we collect about you in the following ways:
- With vendors who perform data or site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
- With vendors to prepare, deploy and analyze advertising content;
- To the extent that we are required to do so by law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our or a third party's legal rights, including providing information to others for the purposes of fraud prevention;
- With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
- With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding or in preparation for any of these events;
- With partners to provide you with information about a mortgage loan, real estate and/or home-related products or services that may be of interest to you;
- With third parties involved in your transaction, such as real estate agents;
- With any other person or entity where you consent to the disclosure; and
- For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.
4. THIRD PARTY SERVICES
Third Party Processors
We use financial information to process your transaction, to improve and expand our service, and to determine your financial health. If you register as a borrower, we will use financial information about you to facilitate your loan request and service your loan. We use this information to process your loan application or transaction and enable payments and fund transfers with financial institutions. If you consent to have NAF request your financial information directly from your financial institution, we may work with a third party to access and collect such information on our behalf.
5. OPT-OUT PREFERENCE SIGNALS
The Sites recognize the Global Privacy Control ("GPC") signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Some internet browsers incorporate a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the "Do Not Track" signal, the Sites do not currently interpret, respond to, or alter their practices when they receive "Do Not Track" signals.
We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.
7. THIRD PARTY LINKS
The Sites may contain links that will let you leave the Sites and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.
8. CHILDREN'S PRIVACY
The Sites and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal data from children under 13.
9. NOTICE TO CALIFORNIA RESIDENTS
The CCPA defines "personal information" to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this "NOTICE TO CALIFORNIA RESIDENTS" section, we will refer to this information as "Personal Information."
The CCPA's privacy rights described below do not apply to Personal Information that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Financial Privacy Notice.
The CCPA's privacy rights also do not apply to certain types of Personal Information subject to the federal Fair Credit Reporting Act ("FCRA"). Some of our services are subject to the FCRA and, therefore, exempt from the CCPA on that basis.
Notice at Collection of Personal Information
- Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number)
- Personal information described in California's Customer Records statute (California Civil Code § 1798.80(e)) (signature, physical characteristics or description, telephone number, bank account number, credit card number, debit card number, or any other financial information (such as bank statements and information about your income and financial obligations), medical information (such as medical debts and disability income), as well as the categories listed in the "Identifiers" category above)
- Characteristics of protected classifications under California or federal law (race, color, sex/gender (including pregnancy, childbirth, and/or related medical conditions), age (40 and older), national origin, disability, citizenship status, marital status, military or veteran status, status as a victim of domestic violence, request for family care leave, request for leave for an employee's own serious health condition, request for pregnancy disability leave)
- Commercial information (records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies)
- Biometric information (voice recordings, from which an identifier template, such as a voiceprint, can be extracted, keystroke patterns or rhythms)
- Geolocation data
- Audio, electronic, visual, or similar information
- Professional or employment-related information (including employment history)
- Education information
- Sensitive Personal Information (Personal Information that reveals a consumer's Social Security, driver's license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation (1,850 ft.); racial or ethnic origin; the processing of biometric information for the purpose of uniquely identifying a consumer)
We collect Personal Information directly from California residents and from advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers. We do not collect all categories of Personal Information from each source.
In addition to the purposes stated in the "HOW WE USE YOUR PERSONAL DATA" section above, we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services
- Providing advertising and marketing services to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance the service
- Advancing our commercial or economic interests, such as by enabling or effecting, directly or indirectly, a commercial transaction
Sale, Sharing, and Disclosure of Personal Information
|Category of Personal Information||Categories of Third Parties|
Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name)
Personal information described in California's Customer Records statute (California Civil Code § 1798.80(e)) (physical characteristics or description, telephone number)
Characteristics of protected classifications under California or federal law (age (40 and older))
Audio, electronic, visual, or similar information
We sold or shared Personal Information to third parties for the following business or commercial purposes:
- Auditing related to counting ad impressions
- Providing advertising and marketing services
- Advancing our commercial or economic interests
|Category of Personal Information||Categories of Recipients|
Identifiers (Social Security number, driver's license number, passport number)
Personal information described in California's Customer Records statute (California Civil Code § 1798.80(e)) (physical characteristics or description, telephone number, signature, bank account number, credit card number, debit card number, or any other financial information (such as bank statements and information about your income and financial obligations), medical information (such as medical debts and disability income))
Audio, electronic, visual, or similar information
Professional or employment-related information (including employment history); Education information
We disclosed Personal Information for the following business or commercial purposes:
- Auditing related to counting ad impressions
- Helping to ensure security and integrity
- Debugging to identify and repair errors
- Short-term, transient use
- Performing services
- Providing advertising and marketing services
- Advancing our commercial or economic interests
We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
If you are a California resident, you have the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling, or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- The right to delete Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate Personal Information that we maintain about you;
- If we sell or share Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or correct through our interactive webform available here or by calling us toll free at (800) 450-2010 Ext. 7100.
As mentioned above, if you are a California resident who has a financial product or service with us, much of the Personal Information that we collect is exempt from the CCPA and, therefore, is not subject to the rights discussed in this "NOTICE TO CALIFORNIA RESIDENTS" section. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Financial Privacy Notice.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the Personal Information, we may ask you to re-authenticate yourself with respect to that account.
If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a "reasonable degree of certainty" or a "reasonably high degree of certainty" depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.
Right to Opt Out of Sale or Sharing of Personal Information
If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.
You may submit a request to opt out of sales or sharing through our interactive webform available here. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the "OPT-OUT PREFERENCE SIGNALS" section above for more information.
Right to Limit Use of Sensitive Personal Information
California residents also have the right to limit our use or disclosure of Sensitive Personal Information if we use it for purposes other than those specified in the CCPA and its regulations. As stated above, we do not currently use or disclose Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations. However, if you are a California resident, you still may submit a request to limit, and we will record your instructions and incorporate them in the future if our policy changes. You may submit requests to limit through our interactive webform here or by calling us toll free at (800) 450-2010 Ext. 7100.
11. MEDIA INFORMATION
12. HOW TO CONTACT US
To contact us for questions or concerns about our privacy policies or practices, please contact us via email at PrivacyRequest@nafinc.com or via telephone at (800) 450-2010 Ext. 7100.