The California Consumer Privacy Act of 2018 (CCPA), provides California residents with specific rights related to their personal information. This section describes what information we collect and your CCPA rights and how to exercise them.
In certain ways described below, we collect information consumers' "personal information", which is 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 device. As used below, "personal information" only refers to information protected under the CCPA.
Use of Personal Information
Embrace does not and will not sell your personal information.
We collect this information for business and commercial purposes that include:
- Providing customer service and financing;
- Performing services;
- Protecting against fraud;
- Compliance with legal reporting and record retention requirements.
We also use Personal Information that we collect about you or that you provide to us, including any Personal Information used to fulfill our contractual obligations to you:
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to your loan or any other products or services we offer.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol internet protocol address, physical characteristics, driver's license or state identification email address, account name, social security number, passport number, or other similar identifiers.
Bank account, credit card, insurance, and other financial information.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, internet website, application, or advertisement.
Professional, educational, and employment-related information.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Inferences drawn from other personal information, such as to develop a profile of your consumer preferences
We collect this information in various ways. We collect most personal information directly from you — either during a mortgage application or as we service your mortgage loan. We collect and secure all of this information in accordance with federal regulations. We also may receive information from other sources, such as an internet advertiser, a mortgage lead generator, your prior mortgage servicer, or government entities from which public records are maintained. And we gather information using cookies and other online tools and technology. But, if you are not logged into your online account, this type of information is not collected or maintained in a manner that is considered personal information. In other words, we collect some information about our anonymous website visitors, but we do not attempt to identify our visitors by name or profile. We only identify you by name when you submit a webform with your personal information or log into your account.
Third Party Disclosure
The information above may be disclosed with the following types of third parties:
- Our affiliates.
- 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.
Right of Access and Right to Delete
California residents have the right to request that Embrace disclose certain information to you about our collection and use of your personal information over the past 12 months, subject to certain exceptions. You can make this request for free, twice per year.
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.
- 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.
You also 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.
Personal information that is collected, held, or processed pursuant to the Gramm Leach Bliley Act or Fair Credit Reporting Act is exempt from the CCPA and not subject to the right to access or right to delete. Additionally, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 et. 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 Your Rights and More Information
To exercise these CCPA rights described above, please submit a verifiable consumer request to us in one of the following ways:
Calling us at 800-333-3004
Emailing us at email@example.com
Online by clicking here:
If you just want more information about our privacy policies and practices, please contact us for questions at the phone number or e-mail address above.
Only you, or a person registered with the California Secretary of State that you authorize in writing 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. An authorized agent must confirm their own identity directly with us.
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 not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we 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.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at:
Embrace Home Loans
25 Enterprise Center
Middletown, RI, United States 02842
You need to provide the statement "My California Privacy Rights" in the subject field of your e-mail or on the envelope or post card and in the actual request. For all requests, please include your name, street address, city, state, and zip code. We will not accept requests via the telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, or that do not have complete information.