California Privacy Policy

Last updated December 2019

PRIVACY POLICY CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS, CALIFORNIA PROPERTY OWNERS AND CALIFORNIA CONSUMERS supplements and incorporates herein as if more fully set forth at length the information contained in the Privacy Policy of Union Home Mortgage Corp. (hereinafter “UHM”) and applies solely to visitors, users, consumers, borrowers and others who reside in the State of California or own property or are in the process of or are considering purchasing property in the State of California (“consumers” or “you”). UHM adopts this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

UHM collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with or to a consumer, individual or device (“personal information”). More specifically, UHM has collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

UHM obtains the categories of personal information listed above from the following categories of sources:

Directly from consumers or their agents. For example, from conversations and discussions and from documents that UHM borrowers provide to UHM related to mortgage loan origination.
Indirectly from consumers or their agents. For example, through information UHM collects and obtains during the mortgage loan origination process.
Directly and indirectly from activity on our website (www.unionhomemortgage.com). For example, from submissions through our website portal or website usage details collected automatically.
From unaffiliated 3^rd For example, an Appraiser or Appraisal Management Company.

Use of Personal Information

UHM may use or disclose the personal information it collects for one or more of the following business purposes:

To provide World Class Service in meeting the reason for which the information is provided. For example, if you provide UHM with personal information for UHM to originate, process, underwrite and close a mortgage loan, then UHM will use that information either partially or during the entire loan process life cycle.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To improve our website and present its contents to you.
As necessary or appropriate to protect the rights, property or safety of UHM, and past, present and future UHM clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, or other sale or transfer of some or all of UHM assets, in which personal information held by UHM is among the assets transferred.

At all times relevant, UHM will not collect additional categories of personal information or use the personal information UHM collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

UHM may disclose your personal information to a third party for a business purpose. When UHM discloses personal information for a business purpose, the recipient is required to both keep that personal information confidential and not use it for any purpose.

In the preceding twelve (12) months, UHM disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category I: Professional or employment-related information.

UHM discloses your personal information for a business purpose to the following categories of third parties:

Our affiliates.
Service providers.
Third parties to whom you or your agents authorized UHM to disclose your personal information.

In the preceding twelve (12) months, UHM has not sold any personal information.

Your Rights and Options

The CCPA provides consumers (California residents, California property owners and those contemplating or purchasing California property) with detailed rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

UHM DOES NOT SELL, NOR DOES UHM INTEND TO SELL, YOUR PERSONAL INFORMATION TO THIRD PARTIES.

Access to Specific Information

You have the right to request that UHM disclose certain information to you about UHM’s collection and use of your personal information over the past 12 months. Once UHM is in receipt of and confirms your verifiable consumer request, UHM will disclose to you:

The categories of personal information UHM collected about you.
The categories of sources for the personal information UHM collected about you.
UHM’s business or commercial purpose for collecting that personal information.
The categories of third parties with whom UHM shared that personal information.
The specific pieces of personal information UHM collected about you.
If UHM disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that UHM delete any of your personal information that UHM collected from you and retained, subject to certain Exceptions. Once UHM receives and confirms your verifiable consumer request, UHM will delete (and direct UHM’s service providers to delete) your personal information from UHM’s records, unless an Exception applies.

UHM may not be in apposition to accommodate your request and UHM may deny your deletion request if retaining the information is required by other Federal and/or State laws, statutes, regulations or rules, which may be in conflict with or supercede the CCPA, or it is necessary for UHM or our service providers to:

Complete the transaction for which UHM collected the personal information, provide a service that you requested, or perform or take actions reasonably anticipated within the context of UHM’s ongoing business relationship with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access and/or deletion rights described above, please submit a verifiable consumer request to us by either:

Calling UHM corporate headquarters at 800-767-4684.
Visiting unionhomemortgage.com and scrolling to the bottom of the Main Landing Page and selection the link for California Consumer Privacy Act

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. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request should:

Provide enough information that permits UHM to reasonably verify you are the person about whom UHM collected personal information.
Describe your request with details that allows UHM to properly understand, evaluate, and respond to it.

UHM cannot timely or accurately respond to your request or provide you with personal information if UHM cannot verify your identity or authority to make the request and confirm the personal information relates to you. PLEASE be advised that submitting a verifiable consumer request does not require you to create an account with UHM. UHM will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

UHM will use best efforts and diligently respond to a verifiable consumer request on or before 45 days of receipt. Should unusual circumstances dictate that additional time (up to 90 days) is warranted, UHM will inform you of the reason and extension period in writing. UHM will deliver a written response by mail or electronically, at UHM’s option. Any disclosures UHM provides will only cover the 12-month period preceding the verifiable consumer request's receipt. UHM’s response may also explain the reason(s) that UHM cannot comply with a request, if applicable.

At this time and until further notice, UHM does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, malicious, repetitive, harassing in nature or manifestly unfounded. If UHM determines that the request warrants a fee, UHM will tell you why UHM made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

UHM does not and will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, UHM will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

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

Contact Information

Should you, the California consumer, have any questions, concerns or comments about UHM’s California Privacy Policy, the manner in which UHM collects and/or uses your personal information, your choices and rights regarding such use, or desire to exercise any and or all of your rights, either singularly or combined, under California law, kindly contact us by either or all of the below 4 methods at:

Phone: 800-767-4684 (to ensure prompt and proper service please mention the CCPA)
Website: www.unionhomemortgage.com
Email for california privacyEmail: CaliforniaConsumerPrivacyAct@unionhomemortgage.com
Email for california consumer privacy By Mail: Union Home Mortgage Attn: Compliance Dept.
8241 Dow Circle West,
Strongsville, OH 44136