This Privacy Notice is specific to California residents and applies to visitors, users, and others who reside in the state of California. This Privacy Notice supplements the information contained in the Veterans Community Home Loans Privacy Notice. California residents (hereinafter referred to as “Consumers”) have rights regarding their information as outlined in the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. All terms defined in the CCPA have the same meaning when used in this Notice
Information We Collect
We collect information that identifies, relates to, and describes, references, may be associated with, or could be linked, directly or indirectly, with a particular consumer or device, known as “personal information.” The information outlined below outlines what we have and have not collected from consumers within the last twelve (12) months.
| Category | Examples | Collected |
|---|---|---|
| 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 |
| 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 |
| 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 |
| Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| 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 |
| Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| Geolocation data | Physical location or movements. | YES |
| Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | YES |
| Professional or employment-related information | Current or past job history or performance evaluations. | YES |
| Non-public education information | Non-public education information 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 |
| Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
As defined in the CCPA, personal information does not include the following:
- Publicly available information from government records
- De-identified or aggregated consumer information
- Information excluded from the CCPA’s scope including, but may not be limited to:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA)
- Personal information covered by federal privacy laws, include the Fair Credit Reporting Act, the Gramm-Leach Bliley Act, and the Driver’s Privacy Protection Act of 1994
Veterans Community Home Loans obtains the collected information outlined above through the following means:
- Directly or indirectly from activity on the Veterans Community Home Loans website. For example, form submissions through our website portal or website usage details collected automatically.
- Directly from our consumers or their agents. For example, information directly provided by you or by someone on your behalf.
- From third-parties that may interact with us in connection with the services we provide. For example, information provided by third-parties
Use of Personal Information
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 you provided the information. For example, if you share information to obtain a quote or receive information regarding a product or service, we will use that personal information to respond to your inquiry. We may also save your information to market new products and services to you.
- To provide you with support, information and to respond to your inquiries.
- To provide you with email campaigns and other notices specific to our products or services that may be of interest to you.
- To complete a transaction that is covered under the requirements set forth in CCPA.
- 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.
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.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories, as previously defined in the Information We Collect section, of personal information for a business purpose:
- Identifiers
- Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Protected classification characteristics under California or federal law
- Professional or employment-related information
We disclose your personal information for a business purpose to the following categories of third parties:
- 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
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers that are California residents with specific rights regarding their personal information.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you to following:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business purposes 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.
Deletion Request Rights
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 request, we will delete your personal information from our records, unless an exception applies. We will also direct our service providers to delete your personal information from their 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.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by utilizing one of the following methods:
- Call us at 1-877-828-9569
- Submitting a request here
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 or data portability twice within a twelve (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.
Response Timing and Format
We will make a good faith effort to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (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 twelve (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 form to provide your personal information that is readily useable 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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not engage in the following:
- Denying you goods or services;
- Charging you different prices or rates for goods or services or imposing penalties;
- Providing you a different level or quality of goods or services;
- Suggesting 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
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 homepage. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
To make a California Verifiable Consumer Request click here to download Declaration Form