Privacy Policy
BROKER SOLUTIONS, INC.
PRIVACY POLICY
Effective as of December 29, 2022
INTRODUCTION
Broker Solutions, Inc. (“BSI,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our websites (“Sites”), the services provided through our Sites and the mobile applications we offer (collectively, “Services”).
From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.
If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Financial Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
This Privacy Policy covers the following topics:
1. COLLECTING AND USING INFORMATION
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
3. THIRD PARTY PROCESSORS
4. “DO NOT TRACK” SIGNALS
5. CHOICES ABOUT YOUR PERSONALLY IDENTIFIABLE INFORMATION
6. SECURITY
7. THIRD PARTY LINKS
8. CHILDREN’S PRIVACY
9. NOTICE TO CALIFORNIA RESIDENTS
10. ACCESSIBILITY
11. HOW TO CONTACT US
1. COLLECTING AND USING INFORMATION
Personally Identifiable Information We Collect Online
We collect Personally Identifiable Information from you through your use of the Sites and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:
Information You Provide
We collect the following Personally Identifiable Information that you may voluntarily provide to us:
• Get a Quote. If you apply to receive a quote, we will collect your first and last name, email address, telephone number, and other general information to customize the service offerings, such as your income range and estimated sale price of the home. As part of this process, you may register for an account.
• Apply for a Loan. If you apply for a loan, we will collect your first and last name, email address, telephone number, postal address, Social Security number, professional or employment-related information, commercial and financial information such as your loan details and payment history, and information about your preferences and needs to customize your service offerings and user experience. We may use a third party to collect some of this information on our behalf. See the section titled, “Third Party Processors” below.
• Contact Us or an Agent. If you request to speak with an agent through our online form, we will collect your first and last name, email address, and telephone number. We will also collect your email address and any Personally Identifiable Information you choose to provide to us when you contact us by email.
• Register for an Account. If you register for an online account to track your loan application and/or manage your loan, we will collect your email address and password.
• Customer Care Portal. If you register to use our Customer Care portal, we will collect your username and password, loan number, Social Security number, email address, and security questions and answers.
• Apply to Join Our Team. If you apply for a job opening or to become a loan officer, we will collect your first and last name, email address, and telephone number and may collect your home address.
• Mobile Apps. If you use our mobile applications, we will collect your account login credentials. We also will collect a device identifier and location to provide additional security to protect your account.
Information as You Navigate Our Sites
We automatically collect certain Personally Identifiable Information through your use of the Sites and Services, such as the following:
• Usage Information. For example, the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
• Device Information. For example, hardware model, operating system, application version number, and browser.
• Mobile Device Information. Aggregated information about whether the Sites are accessed via a mobile device or tablet, the device type, and the carrier.
• Location Information. Location information from visitors to the Sites on a city-regional basis.
Third Party Information
In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, if you apply for a loan, you may provide the Personally Identifiable Information of a coborrower. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.
How We Use Your Personally Identifiable Information
We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Sites, and to protect our legal rights. In addition, depending on how you interact with our Sites and Services, we may use the Personally Identifiable Information we collect to:
• Process your account registration;
• Process your loan application;
• Review your job application;
• Provide member account disclosures and notifications for certain loan activity;
• Respond to your requests, feedback, and inquiries;
• Contact you regarding our products and services that we feel may be of interest to you;
• Communicate with you about our Sites or Services or to inform you of any changes to our Sites or Services;
• Provide support;
• Maintain and improve our Sites and Services;
• Defend our legal rights and the rights of others;
• Efficiently maintain our business; and
• Comply with applicable law.
How We Share Your Personally Identifiable Information
We may share the information that we collect about you in the following ways:
• With service providers who perform data or site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
• To service providers to prepare, deploy and analyze advertising content;
• To the extent that we are required to do so by law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
• To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these events; and
• To any other person or entity where you consent to the disclosure.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
How We Use Cookies
Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).
We use Cookies to:
• Estimate audience size and usage patterns;
• To track how a user arrives at our site;
• Advertise new content and services that relate to your interests;
• Keep track of advertisements and search engine results;
• Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
• Recognize when you return to the Sites.
We set some Cookies ourselves and others are set by other entities. We use Cookies set by other entities to provide us with useful information to help us improve our Sites and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google, Facebook and other similar companies.
How You Can Opt-Out of Cookies
Browser Settings
Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Sites.
You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.
Platform Controls
You can opt out of Cookies set by specific entities by following the instructions found at these links:
• Adobe: https://www.adobe.com/privacy/opt-out.html
• Google: https://adssettings.google.com
• Facebook: https://www.facebook.com/about/ads
• LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
• Microsoft: https://account.microsoft.com/privacy/ad-settings/
• Twitter: https://twitter.com/personalization
• Yahoo: https://policies.yahoo.com/xa/en/yahoo/privacy/topics/opt-outfaq/
Advertising Industry Resources
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
Google Analytics
We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Sites and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.
Google reCAPTCHA
Some of our sites use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Sites from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Use. More information as to Google reCAPTCHA and how it works is available here.
Session Recording
If you are a visitor, we use cookies and other technologies provided by third-party vendors to collect information on your use of the Site/App, such as pages visited, links clicked, non-sensitive information entered, and mouse movements. This information enables us to build and maintain our service based on user feedback and interaction with our Site/App. We also collect information more commonly collected such as the referring URL, browser, operating system, and Internet Protocol (“IP”) address.
3. THIRD PARTY PROCESSORS
To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, we use various cloud data storage; payroll processors; accounting software; payment processors; marketing service providers.
We use financial information to process your transaction, to improve and expand our service, and to determine your financial health. If you register as a borrower, we will use financial information about you to facilitate your loan request and service your loan. We use this information to process your loan application or transaction and enable payments and fund transfers with financial institutions. If you consent to have BSI request your financial information directly from your financial institution, we may work with a third party to access and collect such information on our behalf.
4. “DO NOT TRACK” SIGNALS
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.
5. CHOICES ABOUT YOUR PERSONALLY IDENTIFIABLE INFORMATION
Review and Request Changes to Your Personally Identifiable Information
You may contact us to access, correct, or view certain Personally Identifiable Information we have collected, and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us as described in the “How to Contact Us” section below.
Marketing Communications
To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails.
6. SECURITY
We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
7. THIRD PARTY LINKS
The Sites and Services may contain links that will let you leave the Sites and Services and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired by us on this Sites and Services. We accept no responsibility or liability for these other websites.
8. CHILDREN’S PRIVACY
The Sites and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.
9. NOTICE TO CALIFORNIA RESIDENTS
If you are a California resident, please view our California Privacy Act Disclosure for additional disclosures and rights concerning your Personal Information (defined in the California Privacy Act Disclosure).
10. ACCESSIBILITY
We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you are using a screen reader or other auxiliary aid and are having problems viewing this Privacy Policy, please call (800) 450-2010 Ext. 7100 for assistance.
11. HOW TO CONTACT US
To contact us for questions or concerns about our privacy policies or practices please contact us via email at CustomerService@nafinc.com or via telephone at (800) 450-2010 Ext. 7100.