CCPA
PRIVACY NOTICE FOR CALIFORNIA CONSUMER
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS, as defined by the California Consumer Privacy Act of 2018 and codified in California Civil Code section 1798.10 et seq. (hereinafter “CCPA” or “Act”), supplements the information contained in the Privacy Policy of CITADEL SERVICING CORPORATION (collectively, “we”, “us”, or “our”) and applies solely to all visitors, users, and others who reside in the State of California, (“Consumer” or “you”). In compliance with the CCPA and other applicable California privacy laws, this Notice provides you with our business practices, both online and offline, regarding the collection, use, disclosure and / or sale of your Personal Information and your rights regarding your Personal Information. All capitalized terms not defined herein shall have the same meaning as set forth in the Act. We recommend that you retain a copy of this Privacy Notice for your records.
This Privacy Notice does not apply to employment related Personal Information collected from California based employees, job applicants, contractors, or similar individuals. Our California Employment Privacy Notice is available at www.citadelservicing.com/cepn.
PRIVACY NOTICE – Effective as of January 1, 2020 (Updated July 28, 2020)
PERSONAL INFORMATION WE COLLECT
When you engage with us or use our products and services, we collect a variety of information from and about you. The kind of data we collect about you depends on who you are (broker, borrower, applicant, etc.) and how you use our services. If you are a Consumer who did not complete an application, we will have less information about than if you are an existing borrower for whom we service a loan. Even if you don’t have a loan with us, we may still collect some data about you if you engage us in your professional capacity for information about our products and services.
Generally, 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 household (“Personal Information”). In particular, we have collected the following categories of Personal Information from its Consumers within the last twelve (12) months.
CategoryExamplesCollected
| A. Identifiers. | A real name, alias, postal address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Unique personal identifier, online identifier, Internet Protocol address, cookies, beacon or other similar website related 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, 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. | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered. | 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. | YES |
| I. Professional or employment-related information. | Current or past job history. | 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 federal, state or local government records.
- De-identified or aggregated consumer information.
- Information exempted from the CCPA’s scope, like:
- Information exempted from the CCPA’s scope, like:
- Personal Information covered by certain sector-specific privacy laws, including without limitation, the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994;
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), if applicable.
SOURCES OF PERSONAL INFORMATION
- We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you and your authorized agents. For example, from documents you provide to us related to the services for which you have engaged us.
- Indirectly from you and your authorized agents or representatives. For example, through information we collect from our clients in the course of providing services to you.
- Directly from your activity on our website (www.citadelservicing.com), excluding Unique Identifiers. For example, from submissions through our website or Borrower Portal, or online form.
- From service providers that help us perform the services we provide. For example, from title and escrow companies.
- From third-parties that interact with us in connection with the services we perform. For example, from lead generation companies.
USE OF PERSONAL INFORMATION
- We carefully evaluate how we use data to make sure that we are using your information to personalize our services and provide value for you. We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to provide a loan estimate, we will use that information to prepare loan estimates and submit it for an application.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. In the event we would like to use your Personal Information in a way that is not described here, we will let you know in advance so you can decide if you are comfortable with that use.
SHARING PERSONAL INFORMATION
- We understand that sharing information with third parties is big responsibility. We are committed to only sharing information when needed for a legitimate business or legal purpose, and then only with recipients who will protect the data. When we disclose Personal Information for a business purpose to offer products and services, we enter a written agreement that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any purpose except as need to provide those products and services and only subject to the terms of this privacy policy. When we need to disclose Personal Information to satisfy a legal or regulatory requirement, including responding to a subpoena or other lawful government request, we will share only information as necessary to comply with that requirement. We may also share information if needed to enforce our legal rights, detect or prevent fraud or security concerns and protect public safety. We may share your Personal Information incidental to the sale or securitization of loans. If we are involved in a merger, acquisition or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding we may share your information in connection with that transaction. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information described above for a business purpose:Category A: Identifiers.Category B: California Customer Records personal information categories. Category D: Commercial information.Category I: Professional or employment-related information.We disclose your Personal Information for a business purpose to the following categories of third parties
:- Our partners.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
YOUR RIGHTS AND CHOICES
- The CCPA provides Consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.Your Right to Know and Access the Personal Information That Is Collected About You.You have the right to request that we disclose certain Personal Information to you about our collection and use of your Personal Information over the past 12 months. We shall not be required to provide personal information to a consumer more than twice in a 12 month period and are not required to retain any Personal Information collected for a single, one-time transaction, if such information is not sold or retained by us and not maintained in a manner that would be considered Personal Information.You also have a right to access your Personal Information and request a copy, which at our sole discretion may be delivered by mail or to the extent feasible, in a readily usable portable electronic format, of your Personal Information that we collected, used, disclosed or sold over the past 12 months.Once we receive and confirm your Verifiable Consumer Request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling 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 (also called a data portability request).
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
To submit a Verifiable Consumer Request:
Please complete the California Consumer Privacy Act Request Form located at www.citadelservicing.com/CCPA and submit it to [email protected]. Be sure to review the Instructional Guide on how to complete the form to ensure that you provide CSC the required information that corresponds to your request. It is important that you follow the instructions provided as your request could be denied if we are unable to verify your identity. Depending on the nature of your request, we may contact you to request additional information.
If you are a Consumer designating an authorized agent, or are an authorized third-party representative of a Consumer making a request on behalf of a Consumer, please ensure that you also complete and submit a CCPA Third-Party Authorization Form available at www.citadelservicing.com/CCPA.
RIGHT TO REQUEST DELETION OF YOUR PERSONAL INFORMATION
- You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm 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 deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- 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 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- 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.
DO NOT SELL MY PERSONAL INFORMATION
- Please be advised that the we do not and have not sold any personal information in the last twelve months. See our Privacy Notices for full details. We do not have any future plans to sell personal information. If that changes, we will provide you advance written notification so that you may understand and exercise your right to “Opt-Out” of the sale. We will provide you with information on how to request that we “Do Not Sell Your Information.” We encourage you to periodically check our website for updates to our privacy policy.
RIGHT TO NON-DISCRIMINATION
- We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services.
- Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of services.
- Suggest that you may receive a different price or rate for services or a different level or quality of services.
EXERCISING YOUR RIGHTS
- To exercise your rights as described above, please submit a Verifiable Consumer Request to us by:
- Filling out the CCPA Request Form per the Instructional Guide and a Third-Party Authorization Form, if applicable.
- By visiting www.citadelservicing.com/CCPA
- Emailing us at [email protected]
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 only make a verifiable consumer request twice within a 12 month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will provide you with an acknowledgement of your request within ten days of your submission. We may contact you if we require additional information to process your request. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
CHANGES TO OUR PRIVACY NOTICE
- We reserve 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 through a Notice on our website or other direct communications like email or mail. We encourage you to periodically review our Privacy Notice to stay informed about our data protection practices and the ways you can help protect your privacy.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: (949) 900-9930 or toll free (888) 800-7661
Website: www.citadelservicing.com/CCPA
E-mail: [email protected]
Postal Address:
Citadel Servicing Corporation
Attn: Legal Dept.
3 Ada Parkway, Suite 200A
Irvine, CA 92618
