As a company built on customer service, we know a thing or two about privacy. Select one of the Privacy Sections below or scroll down to read our privacy principles.
We may use Personal Information as permitted by law, for the following business purposes:
To the extent permitted by law, all of your Personal Information may be disclosed to the following categories of third parties:
We may participate with another company or individual for purposes of jointly promoting our products, services, promotions or contests or their products, services, promotions, or contests. We reserve to right to disclose your personal information and usage data that you generate to them for purposes of (i) compensation, transaction processing, fulfillment, and support, and (ii) for purposes of offering you other products, services, promotions, and contests. These joint venture marketing partners may also contact you regarding other products, services, promotions, or contests.
With recent events and regulatory changes, our customers and business partners are increasingly asking how Generation protects the sensitive information entrusted to us. We recognize that this is a significant trust and one that we don’t take lightly. Information Security is a very complex subject, and the technical details are beyond the scope of this document. However, this document will provide a general overview of the Information Security Controls in place and operating at Generation. The Generation Information Security Program relies on the National Institute of Standards and Technology (NIST) 800 series of standards as the primary framework for our control design, implementation and operation. Those controls include Physical, Technical, Administrative and Procedural controls. We continually invest in and enhance these controls to meet new threats and vulnerabilities. We work with several leading Information Security firms which assist us in the implementation, operation and review of our security controls. This includes periodic assessments and testing. A significant part of our strategy is our implementation of application virtualization technology throughout Generation. This technology significantly reduces the potential attack points by centralizing the location of borrower data within our datacenters. We replicate data between servers in our primary and secondary data centers – data is never put on tape or other physical media for transport. Additionally, all of our associates are provided training on the protection of borrower information and are engaged in an active, continual Information Security Awareness program that keeps Information Security in focus all throughout the year. Generation’s primary tool for loan processing is the Encompass Loan Origination system by Ellie Mae. Additional services (Credit Reporting, Anti-fraud, etc…) are provided by third party organizations via the Ellie Mae Network. Data movement between Ellie Mae software clients to the central server is encrypted throughout transmission. Borrower information stored on the central server is also encrypted while “at rest”. Similarly, information passed through the Ellie Mae Network is encrypted throughout transit. Secure exchange of information between borrowers and Generation Loan Officers and associates is facilitated by the Encompass eFolder functionality. Additionally, our email system is configured to automatically establish Transport Layer Security with any correspondent email systems that support this encryption mechanism. Finally, we have an Encrypted Email system for communications with those that don’t have access to a secure email system. We use standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your Personal Information. Unfortunately, no system or network can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us in accordance with the “Contacting Us” section below (note that physical mail notification will delay the time it takes for us to respond to the problem).
We do not intend for our websites or other online services to knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow minors under the age of 13 to disclose their Personal Information to us through the Sites. The Sites are directed to individuals who are permitted to share their Personal Information without parental consent. If you believe that we might have any information from a child under the age of 13, please contact us as directed below in the “Contacting Us” section. You may mark your inquiry “COPPA Information Request.” Parents can learn more about how to protect children’s privacy online here.
Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in any emails to us.
WHAT IS A COOKIE AND WHY DO WE USE THEM?
Cookies are small pieces of text. They are provided by most websites and stored by your web browser on the computer, phone, or other device that you are using. Cookies serve many purposes. They can help a website remember your preferences, learn which areas of the website are useful and which areas need improvement, and provide you with targeted advertisements or personalized content. Sometimes, cookies are enabled when pixels are placed on a website. Pixels are also referred to as web beacons, clear gifs, and tags. They enable websites to read and place cookies.
FIRST-PARTY COOKIES AND THIRD-PARTY COOKIES
Cookies can be first-party or third-party. A first-party cookie is one that you receive directly from Generation when visiting our Site. A third-party cookie is one that you have received from another party, such as Google or Facebook. We do not control what third parties do on other sites. However, we may work with certain third-party providers such as Google or Facebook to permit their cookies to function through our Site so we can learn more about your web experience on our Site and better personalize our services for you.
PERSISTENT AND SESSION COOKIES
A persistent cookie is a cookie that is stored by the web browser on your device until it expires or you delete it. The expiration of a persistent cookie is determined by the creator of the cookie and can be upon a certain date or after a length of session time has passed. This means that, for the cookie's entire lifespan, its information will be transmitted to the creator’s server every time the user visits the website that it belongs to or another website configured to check for that cookie (such as an advertisement placed on that website). For this reason, persistent cookies are also called “tracking cookies.” A session cookie is created temporarily on your device for use by a website during your visit. This type of cookie may store information you enter and track your activity within the website. A session cookie is deleted after you leave the website or when the web browser is closed. A good example of a session cookie is the shopping cart on an e-commerce site. The session cookie stores the items that you add to your cart so they are not forgotten while you view products on other pages of the website. Using a session cookie, the items will all be in the cart when you go to the checkout page.
HOW DO I MANAGE COOKIES?
Most web browsers let you choose whether to accept cookies. Most also let you delete cookies already set. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options”, “tools” or “preferences” menu. You may also consult the browser’s “help” menu. For example: Cookie settings in Internet Explorer Cookie settings in Firefox Cookie settings in Chrome Cookie settings in Safari There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org. Usually, deletion of cookies will anonymize the information associated with the pixel and a website will not receive any further associated information.
WHAT KIND OF COOKIES DO WE USE?
The Site may use Strictly Necessary Cookies, Performance Cookies, Functional Cookies, Targeting Cookies and Social Media Cookies. Any of these may be first-party cookies or third-party cookies, persistent or session.
Strictly Necessary Cookies: These are cookies without which you would not be able to use this Site. For example, Strictly Necessary Cookies adjust the Site data transmitted to match your Internet connection, get you to the secure versions of the Site, and help provide services you specifically request. If you set your browser to block these cookies, some parts of the Site will not work. Strictly Necessary Cookies do not store any Personal Information.
Performance Cookies: We may use these cookies to count visits and traffic sources, to measure and improve Site performance. They help us to know which pages are the most and least popular and see how visitors move around the site. Performance Cookies do not store any Personal Information.
Functional cookies: These cookies allow the Site to remember choices you make and provide enhanced functionality and more personalized features. Depending on context, Functional Cookies may store certain types of Personal Information as needed to provide functionality.
Targeting Cookies: Targeting cookies help us manage and display our advertisements, based on your activity on the Site and other sites; this is known as interest-based advertising. Targeting cookies mainly rely on uniquely identifying your browser and internet device. Opting out of interest-based advertising does not mean you will no longer see advertising online, but it does mean that the companies from which you opt out will no longer show ads that have been tailored to your interests.
Social Media Cookies: Social Media Cookies make social sharing easier for you, provide you with tools to connect with the Site, and help us better understand both the audience for the Site and the effectiveness of our social media outreach. These are third-party cookies. Your choices with respect to such cookies are determined by the social media platforms on which you have accounts.
CONTACTING US If you have any further questions, please contact us by calling (800) 447-2603.
You have the right to know and see what data we have collected about you over the past 12 months, including: The categories of Personal Information we have collected about you; The categories of sources from which the Personal Information is collected; The business or commercial purpose for collecting your Personal Information; The categories of third parties with whom we have shared your Personal Information; and The specific pieces of Personal Information we have collected about you.
You have the right to request that we delete the Personal Information we have collected from you by clicking here. There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following: Complete your transaction; Provide you a good or service; Perform a contract between us and you; Protect your security and prosecute those responsible for breaching it; Fix our system in the case of a bug; Protect the free speech rights of you or other users; 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 interests that adheres to all other applicable ethics and privacy laws; Comply with a legal obligation; or Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
You also have the right not to be discriminated against for exercising any of your rights.
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 device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months: Click here
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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
The categories of sources from whom we collected this Personal Information are:
Directly from a California resident or the individual’s representatives Service Providers, Consumer Data Resellers and other third parties Public Record Sources (Federal, State or Local Government Sources) Information from our Affiliates Website/Mobile App Activity/Social Media Information from Client Directed Third Parties
Affiliates of Generation Lending Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities Partners and Third Parties who provide services Other Third Parties who enable customers to conduct transactions online and via mobile devices and support mortgage and fulfillment services Government Agencies as required by laws and regulations
To request access to or deletion of your Personal Information, or to exercise any other data rights under California law, please contact us using one of the following methods: WEBSITE - You may visit our online request form to authenticate and exercise your rights. PHONE - You may dial our Customer Service at (844) 933-3474. OTHER DESIGNATED METHODS - We only have two designated methods for submitting your verifiable consumer request, and currently we do not accept requests via US mail. This is to protect you – and us – from fraudulent activity. RESPONSE TIMING AND FORMAT - We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
WHAT IS “PERSONAL INFORMATION” AS DEFINED IN THE CALIFORNIA REGULATION?
Personal Information is practically anything that identifies, relates to, describes or could be associated with you. Beyond your name, phone number, or email address, it includes the kind of device you're using to read this or which web browser. Personal Information also includes biometric data, your geolocation and even your perceived preferences. It does not include publicly available information.
DO YOU SELL MY PERSONAL INFORMATION?
No, we do not. In order to sell your information, we would need to first disclose to you our sale practices AND provide you with an easy “DO NOT SELL MY INFO” button on our website for you to opt-out of future sales of your Personal Information. But rest assured, we do not sell your Personal Information.
HOW AND WHERE DO YOU COLLECT PERSONAL INFORMATION?
That depends. We collected most of this information directly from you — either during a mortgage application or as we service your mortgage loan. Such Personal Information includes social security number, employment history and bank account numbers. 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. 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 web form with your Personal Information or log into/register on our Generation Lending customer portal.
WILL YOU DELETE MY INFORMATION IF I REQUEST YOU DO SO?
The short answer is maybe. The CCPA requires businesses that collect Personal Information directly from consumers to delete such information upon request. Unless the deletion request is subject to an exception. Or an exemption. Let us explain in more detail. Information we collect, store, or share in connection with providing you a financial product or service is exempt. That’s because your financial information is already regulated by federal law. Pursuant to federal law, we leverage administrative, physical and technical methods to safeguard your information. And even if you’re not a customer of ours, we might need to keep some of your information to: complete a transaction, prevent or detect fraud, or comply with a legal obligation. While we may not delete your information, we will always use it for a lawful purpose that aligns with what you would expect given your relationship with Generation Lending.
CAN I REQUEST A COPY OF WHAT YOU COLLECTED OR SHARED?
Well, in some cases, yes and in some cases, no. The CCPA refers to this as your “Right to Know”. But like we mentioned above, the CCPA does not apply to most of the information that we collect or share in our role as a financial institution. We won’t include any of that information in your “Right to Know” response. But we might have other information that is not exempt.
To submit a request, feel free to call us at (844) 933-3474
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