Change Lending, LLC, Privacy Policy

Change Lending, LLC, dba Change Home Mortgage and Change Wholesale (referred to herein as “Change Lending”), values your patronage and protecting your confidential information is a priority. Our policies and procedures reinforce the fact that Change Lending strongly believes in protecting the confidentiality and security of the information we collect about you as a customer, potential customer, or former customer. We have adopted the following policies and procedures that apply to all internet websites that Change Lending operates to safeguard the personal information about you in our possession.

Introduction

Our Privacy Pledge

We do not sell or rent customer information.
We share customer information with certain employees and with companies providing services on our behalf in order to service your needs.
Our policy is to require all employees and companies providing services on our behalf to keep customer information confidential.
Our privacy policy applies to potential customers as well as current and former customers.

Safeguarding Personally Identifiable Information

We have adopted policies and procedures designed to protect your personally identifiable information from unauthorized use or disclosure.
We have implemented physical, electronic and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorized access. These include among other things, procedures for controlling access to customer files, building security programs and information technology security measures such as the use of passwords, firewalls, virus prevention and use detection software.
We continue to assess new technology as it becomes available and to upgrade our physical and electronic security systems as appropriate.
Our policy is to permit employees to access your personal information only if they have a business purpose for using such information, such as administering, providing or developing our products or services.
Our policy, which governs the conduct of all of our employees, requires all employees to safeguard personally identifiable information about the consumers and customers we serve or have served in the past.

Change Lending Security Policy

Change Lending takes strong steps to safeguard your personal and sensitive information through industry standard physical, electronic and operational policies and practices. All data that is considered highly confidential data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls and servers with tested operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.

Information We Collect About You

Enabling our financial services partners to implement automatic payments and funds transfer
Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
Implementing collection activities as needed
Maintaining regular communications with you as may be necessary to execute loan application, loan agreement and certain stipulations such as identity verification, income verification and employment verification
Our policy, which governs the conduct of all of our employees, requires all employees to safeguard personally identifiable information about the consumers and customers we serve or have served in the past.

In addition, we gather names and email addresses of people who contact us through our website with questions about our company or lending operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people.

Lastly, we (and/or our service providers) collect information about your computer and your visits to our website, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our website to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies, and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our website based on the needs of our users. Additionally, third parties may collect certain similar information about your computer and other pages you may visit when you visit our website, as discussed further below.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Communications from Our Site, Including Sites of Our Affiliates

When you submit an application and/or create a profile on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses and the bank accounts, and confirmation of successful submissions of loan requests and portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.

Links to Third Party Websites

Change Lending is not responsible for the information practices employed by sites linked to or from our website. In most cases, links to websites that are owned or operated by companies other than Change Lending (“third-party websites”) are provided solely as an access point to obtain information on products and topics that may be useful to the users of Change Lending website. Third-party websites may have different privacy policies and/or security standards governing their sites. When you use a link online to visit a third-party website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the third-party website before providing any information on that website.

Testimonials

Notifications

Change Lending will send you email notifications from time to time, and these are required elements of your transactions on our website, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a borrower or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new email address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements, terms and condition updates and privacy policy update notifications. Generally, you may not opt out of these eservice related emails.

Sharing Information with Companies That Provide Services for Us

We share personally identifiable information about you, as required or permitted by law, with third parties, such as service providers who assist us in the in the administration, processing, servicing, and sale of your loan. These third parties include among others, title companies, appraisers, insurance companies, underwriting services, processing services, printing companies, software providers, marketing services, and purchasers of loans. Our policy is to require third party service providers to enter into confidentiality agreements with us, prohibiting them from using any personally identifiable information they obtain for any other purpose other than those for which they were retained or as required by law. We may also disclose information about you, when necessary or required, in legal and arbitration proceedings and to government agencies.

Where You Can Find and/or Correct Your Information

Web-related Information Collection

Change Lending uses web beacons or pixel tags in conjunction with cookies on our website, including session ID cookies, non-persistent cookies. A cookie is a text file sent by a web server to a web browser and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser and load the pages according to a user’s preferences for that particular site, including the personalization of content. Cookies are also used to gather statistical data, such as which pages are visited, what is downloaded, the ISP’s domain name and country of origin, and the addresses of sites visited before and after coming to our site, as well as your “click stream” activity, meaning the paths taken by visitors to our site as they navigate from page to page and transactional attributes in accordance with information you voluntarily submit in the course of using our site. This data is aggregated for analysis to ensure proper functioning of our site in terms of navigation and usability, as well as to evaluate the effectiveness of our marketing activities. At no time do any of our cookies capture any personally identifiable information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Cookie Policy. More importantly, using cookies also helps us protect the security of your account. Encrypted session ID cookies follow your activities on our site so that we can ensure that no one is making changes to your profile, applying for loans, or making loans on your behalf. We may send a cookie that can be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of our website, to improve its usability and for evaluating our marketing events. We may also use that information to recognize your computer when you visit our website. Most browsers allow you to refuse to accept cookies. Blocking cookies, however, can also have a negative impact on the usability of many websites. We also use third-party tracking services that use cookies or other tracking technology to track non-personal information about visitors to our site in the aggregate such as web page views, other sites visited and referral page information to track the effectiveness of our marketing campaigns to bring visitors to our site. We use respective web beacons to gather information that lets us tune and improve the user’s browsing experience, as well as track user responsiveness to various advertising campaigns and user activities. No personal or sensitive information is transmitted to advertising partners. However, certain partners may collect incoming IP addresses in connection with your visits to our site.

This site uses the Google Maps API, the Google Places API and the Google Maps Geocoding API to collect information about your location. By using this site, you agree to allow us to cache your location for the uses described herein. You may revoke this consent at any time by disabling geolocation sharing in your browser and starting a new browsing session. This information is used to identify nearby branch locations and provide directions to those locations and such information is only retained during your browsing session. Google’s Privacy Policy is incorporated herein and can be found at https://policies.google.com/privacy. By using this site, you agree to be bound by Google’s Terms of Service which may be found at https://policies.google.com/terms.

If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. On your Apple mobile device, go to Settings, then Safari, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. If you want to disable cookies and you’re using the Chrome browser, go to Settings > Privacy and Security > Cookies and Other Site Data, make the selection that provides the level of tracking you prefer. If you want to disable cookies and you’re using the Explorer browser, go to Settings > Internet Options > Privacy Tab > Advanced, make the selection that provides the level of tracking you prefer. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of Change Lending website will not be available once cookies are disabled.

California Do Not Track Notice

Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about a consumer’s online activities over time and across third party websites, to the extent the operator engages in that collection. At this time, we do not track our customer’s personal information over time and across third-party websites and therefore this requirement does not apply to us. California law also requires website and online service operators to disclose whether third parties may collect personal information about their user’s online activities over time and across different sites when the users use the operator’s website or service. Third parties that have content or services on our site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. We do not knowingly permit such third parties to collect any personal information from our site unless you directly provide it to us and we provide it to them with your consent.

California Consumer Privacy Act (CCPA)

Children’s Online Privacy Protection Act

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our customers. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Link to Other Sites

We may offer links to partners’ sites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled or to facilitate our customers’ more effective use of our website, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this privacy policy and may have different privacy policies or approaches to the handling of information. Change Lending has no control over the content of these sites. Please consult the privacy policies on these sites before you provide them any of your personal information.

We also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our website you are actually on our site. SSL also ensures that all data entered into the website is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For encryption protection, we use 128-bit secure browser for login and transactions. The application process utilizes “CAPTCHA” technology, which is a test that we use to ensure certain sensitive transactions are being initiated by a human and not by another computer. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering the text shown in the image. We subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.

Session time-outs

Passwords

At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an email purporting to come from Change Lending that asks for your password, you should immediately contact us.

What you can do

You can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and you can also use specifically characters in place of letters. We also recommend that you change your password often. You can also install and update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.

To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your email account. Therefore, you might consider restricting access to the email account you registered with on this site and/or changing your password on that email account frequently.

If you use a computer that is accessed by other people, such as in a public library or internet café, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using your site, you should log out completely, then close the browser window and clear the browser’s cache file.

You should also be aware of fraudulent attempts to gain access to your account information known as “phishing”. Phishing is a tactic used by scammers in which unsuspecting people are brought to a website by a genuine-looking email purporting to be from a legitimate company. The phony or “spoof” email takes the person to a website that looks legitimate but in fact is not. Either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money. Change Lending will never ask for login information to gain access to customer’s account and access sensitive information. Change Lending will never ask you for your login information in the context of any email, physical mail, phone call or otherwise. In general, you can protect yourself against phishing by never providing personal or login information via an email instead, go to the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain.

Changes to Our Privacy Policy

We may make changes to our privacy policy in the future. If you choose to receive e-mail messages or newsletters from us, you may later modify your choice by contacting us at phone number 1-833-CHM-0123. You will also be given the opportunity, in any general bulk commercial e-mail that we send to you, to opt out of receiving such messages in the future. We will attempt to address your request immediately but it may take up to ten (10) days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as processing requests, conditional loan offers, requests for additional information, service updates or announcements, administrative notices and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of promotional e-mail communications will only affect future activities or communications from us. Note: If we have already provided your information to a third party as part of your loan application then you may have to change your preferences directly with that third party.

Our Do Not Call policy states that you may instruct us not to call you for marketing purposes by informing us at phone number 1-833-CHM-0123. Our employees are trained through Policies and Procedures to take action on your instructions within thirty (30) days. Please note that we may still need to contact you for legitimate business reasons such as servicing of your loan or other non-marketing purposes.