COMPANY PRIVACY POLICY
This Privacy Statement ("Statement") describes the policy adhered and enforced by International City Mortgage, Inc. DBA Doorway Home Loans, NMLS ID #222730 (herein after referred to as "Doorway" or "we", “us”) for collecting, managing, and using personal and corporate information collected by our employees and through our websites and mobile applications.
Doorway is committed to respecting and protecting the personal privacy of its Customers, users and those who visit its Web site. Keeping financial information secure is one of our most important responsibilities. We maintain physical, electronic, and procedural safeguards to protect Customer information. It is our policy to acquire personal information from users only by overt and voluntary means, only when it is in the interest of the Customer to provide it, and to utilize this information only for the purpose it was provided. Appropriate employees are authorized to access Customer information for business purposes only.
The information that follows explains the kinds of information we collect, how it is used, the conditions under which it is made available to third parties, how information is maintained, and our compliance with the Children's Online Privacy Protection Act. Doorway knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly.
What Information Do We Gather and How Is It Used?
Doorway collects information from our users in different ways. Users can contact Doorway via voice (phone communication), electronic FAX, social media, personal contact, and via web sites.
Customer information is categorized in the following ways:
· Identification Information: “Personal Information” that identifies you such as name, address, telephone number and Social Security number. This information is necessary to properly quote interest rates and eligibility for products provided by us.
· Application Information: Information provided to us via an application form and through other means that will help us determine your eligibility for products you request. Examples of information requested include assets, income, and debt.
· Consumer Report Information: Information from a consumer report. As an example, credit report information furnished by Experian, Transunion, or Equifax.
· Information from Outside Sources: Information from outside sources regarding employment, credit and other relationships that will help us determine if you are eligible for products you request. Examples include employment history, loan balances, credit card balances, property insurance coverage and other verifications.
· Other General Information: Information from outside sources, such as data from public records that is not assembled or used for the purpose of determining eligibility for a product or service. As required by the USA Patriot Act, we also collect required information and take actions necessary to verify your identification.
· Web Site Information: Doorway web server collects aggregate data, such as geo location, device MAC addresses, time on pages, and the number of access attempts by page. Doorway may collect information from you before allowing access to certain resources and personalization features on the web site, or to request a quote, order products and services. Generally, when Personal Information is collected, it is used by Doorway to improve Web content; to respond to visitors' interests, needs and preferences; and to develop new products and services. Doorway does not share Personal Information with any third parties except where user has further approved the release of such information (for example the ordering of credit reports and home appraisals) where might be needed to determine loan feasibility or quote rates.
Cookies
We might send cookies to your computer in order to uniquely identify your system’s browser and improve the quality of our service. "Cookies" refer to small pieces of information that a website sends to your computer's storage drive while you are viewing the Site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). Persistent cookies can be removed by following your browser help file directions. If you choose to disable cookies, some areas of the Site may not work properly or at all. These cookies collect information about your use of the Site, such as where you came from, which pages you visited within the Site, and possibly other sites you visit if those sites cooperate with the same third party, but DO NOT collect your name, email address, contact information or other personally identifiable information that by itself would allow the third party to identify or contact you.
Log Files
Like most standard web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information.
Links
The Doorway web site contains links to other sites or site specific content. Please be aware that Doorway is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by Doorway’s Web site.
Sharing
LEGAL DISCLAIMER: ALTHOUGH WE MAKE EVERY EFFORT TO PRESERVE USER PRIVACY, WE MAY NEED TO DISCLOSE PERSONAL INFORMATION WHEN (I) REQUIRED BY LAW WHEREIN WE HAVE A GOOD-FAITH BELIEF THAT SUCH ACTION IS NECESSARY TO COMPLY WITH A CURRENT JUDICIAL PROCEEDING, A COURT ORDER OR LEGAL PROCESS SERVED ON OUR WEB SITE; OR (II) NECESSARY TO PROTECT AND DEFEND THE RIGHTS OR PROPERTY OF Doorway OR Doorway AFFILIATES, INCLUDING THEIR WEB SITES. EXCEPT AS EXPRESSLY STATED IN THIS PRIVACY STATEMENT, IN NO OTHER CIRCUMSTANCES DO WE SHARE ANY PERSONAL INFORMATION WITH ANY PARTNERS, SERVICE PROVIDERS OR OTHER THIRD PARTIES. WE MAY HOWEVER SHARE AGGREGATE DATA WITH THIRD PARTIES WHERE SUCH DISCLOSURE DOES NOT ENTAIL THE DISCLOSURE OF ANY PERSONALLY-IDENTIFIABLE INFORMATION.
Security
This Web site takes commercially reasonable precautions to protect our users' information. All information entered by a user on the site is encrypted and is protected with SSL encryption software. All purchase transactions that occur on our store are transmitted via an SSL secure server with a digital certificate. We do not store credit card numbers of any sort in our online store for security purposes. If users have any questions about the security at our Web site, users can send an email to info@doorway.com.
Opting out and Correcting Personal Information
If a user's personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service they should contact their assigned representative or email our Customer Support Department at info@doorway.com.
Notification of Changes
If we decide to change our privacy policy, we will post those changes to this Privacy Statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected. If, however, we are going to use users’ Personal Information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their Personal Information in this different manner. However, if users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted, nor will their Personal Information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our web site notifying users of the change. In some cases where we post a notice we will also email users who have opted to receive communications from us, notifying them of the changes in our privacy practices.
Children's Online Privacy Protection Act (COPPA) of 1998
Therefore, Doorway does not use its Site to collect any personally identifiable information from children under 13 years of age. Any input form that requests personally identifiable information that appears on an interface that is expected to be viewed by children under 13 years of age is accompanied by a notice that submissions cannot be accepted from users under 13 years of age. Where "age" or "date of birth" is requested, no information will be stored or transmitted unless the response indicates that the user is 13 years of age or older. Doorway adheres to provisions of COPPA 1988, including new provisions introduced July 1st, 2013. If you become aware that your child has provided us with personal information without your consent, please contact us. If we become aware that a child under 14 has provided us with personal information without parental consent, we will take steps to remove their information and terminate the child's account.
Actions You Can Take
If you have any questions, suggestions, or complaints regarding our privacy policy, please speak directly with your Loan Officer or contact us via any of the following methods:
Phone: (714) 637-6200
Email: info@doorway.com
Mail: 200 E. Sandpointe Avenue, Suite 650, Santa Ana, CA 92707
Attention: Compliance
Other Privacy Commitments
This Privacy Policy includes provisions specified in the “Do-Not-Call” Registry Act of 2003 under the Telephone Consumer Protection Act for all consumers and as pursuant to state law. When you talk with a representation of Doorway by telephone, your conversation may be monitored or recorded by us. You may have other privacy protection rules under state laws, such as Vermont and California. To the extent these laws apply, we will comply with them to the best of our ability.
For Nevada Residents Only
We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions in the Section titled “Actions You Can Take.” Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.
For Vermont and California Residents Only
The information-sharing practices described in this policy are in accordance with federal law. Vermont and California law places additional limits on sharing information about Vermont and California residents so long as they remain residents of those states.
Vermont: In accordance with Vermont law, Doorway will not share information we collect about Vermont residents with companies outside of Doorway except as permitted by law, such as with the consent of the customer, to service the customer’s accounts or to other financial institutions with which we have joint marketing agreements. Doorway will not share Application Information, Consumer Report Information and Information from Outside Sources about Vermont residents among the Doorway companies except with the authorization or consent of the Vermont resident.
California: In accordance with California law, Doorway will not share information we collect about California residents with companies outside of Doorway except as permitted by law, such as with the consent of the customer, to service the customer’s accounts or to fulfill on rewards or benefits. We will limit sharing among our companies to the extent required by applicable California law.
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