Verus collects personally identifiable information from you through the Site when you contact us through the Site’s contact form, submit an application for employment, or create an account for our correspondence portal, including information such as your name, address, email address, phone number, information about your employment or income history, or other information you choose to provide to us. This information is collected and stored electronically when you submit it to us through the Site.
Information Collected Automatically
In addition, information about your computer hardware and software is automatically collected by Verus when you use the Site. This information may include: your IP address, browser type, domain names, access times, geographic location, referring website addresses and other technical information such as protocol status and substatus, bytes sent and received, and server information. We may also collect information about how you interact with the Site. This information is used by Verus for its business purposes, including for the operation and improvement of the Site, for technical troubleshooting, to maintain quality of the Site and to provide general statistics regarding use of the Site.
Cookies and Other Information Collection Tools
What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.
How do I control cookies? Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site.
How Information is Used
We may use the information we collect for any of the following purposes:
• to provide the Site to you and to optimize and improve the Site;
• for customer service, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
• for research and analysis purposes;
• to fulfil your requests; and
• to communicate with you.
Sharing of Information
With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analysis and research Site, to send out email updates about the Site or remove repetitive information from our user lists.
For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.
Changes of Control. We may transfer information, including your personal information, in connection with a change of ownership or control by or of us or any affiliated entity (in each case whether in whole or in part).
Verus does not share your personal information with third parties for those third parties’ marketing purposes.
Security Used & Retention of Personal Information
Verus uses reasonable security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition or misuse of personal information, however, we will not be responsible for loss, corruption or unauthorized acquisition or misuse of personal information that you provide through the Site that is stored by us, or for any damages resulting from such loss, corruption or unauthorized acquisition or misuse. Verus will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.
Links to External Websites
Do Not Track
Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.
We do not knowingly collect or maintain personal information from any person under the age of thirteen. No parts of our Site are directed to or designed to attract anyone under the age of thirteen.
Contact Information; Questions and Changes in Information
Notification of Changes
Definition of Personal Information
We collect certain "personal information" from Consumers. The CCPA defines personal information as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated information.
- Information excluded from the CCPA's scope:
- 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 other privacy laws, like the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and California Financial Information Privacy Act (FIPA).
What Personal Information We Collect
We have collected the following categories of personal information from Consumers within the last twelve (12) months:
|A. Identifiers.||Real name, alias, postal address, personal and work phone number, unique personal identifier, online identifier, Internet Protocol address, personal and work email address, account name, Social Security number, driver's license number, passport number, and other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or similar network activity.||Browsing history, search history, information on a Consumer's interaction with a website, application, or advertisement.||NO|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history, responsibilities, memberships or performance evaluations, national identification information, travel-related records, background check and screening results, references, EEOC monitoring information (ethnicity, religion, gender and sexual orientation).||YES|
|J. Non-public education information||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Categories of Sources
We obtain the categories of personal information listed above from:
- Third-party originators from which we buy or consider buying loans, from our loan servicing agents and from our service providers in connection with the purchase and sale of such loans.
- Other third-parties from whom we obtain products or services for credit and due diligence purposes.
How We Use Personal Information
We may use or disclose personal information we collect for one or more of the following business purposes:
- To fulfill the request or satisfy the reason for which the information is provided. For example, if a third-party loan originator provides us with personal information in order for us to consider buying a loan, we use that information to assess the eligibility of the loan for purchase.
- In connection with activities related to our secondary market activities of buying and selling mortgage loans. For example, we use personal information to evaluate loans that we are considering buying and to monitor the performance of loans of loans owned by our affiliates.
- To establish and manage our relationships with third party loan originators and other counterparties with whom we conduct business. This may include names, email addresses, phone numbers and other contact information for the employees of the counterparties with whom we conduct business.
- If you send us an email or message and provide your name or other personal information, we may use this information to research your question, to send an answer to your question and to deliver the requested information or service to you.
- With regard to website visitor information, to measure the number of visitors to different pages on the website, evaluate, modify and enhance our website.
- In connection with employment applications to the Company.
- To carry out our obligations and enforce our rights arising from any loan documents or other contracts we have entered into, including for collections.
- As required by applicable laws, regulations and court orders, and requests from Congress, our regulators, or our conservator.
- To respond to law enforcement requests.
- For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, or other misconduct.
- To establish or defend legal claims and allegations.
- To seek advice from lawyers, auditors and other professional advisers.
We do not take the following action with your personal information:
- We do not sell personal information to third parties for advertising or marketing products and services to you, or to third parties whose purpose in acquiring the information is to sell your personal information to others for advertising or marketing purposes.
- We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without first providing you notice in the manner specified in the "Changes to this Policy" section of this Policy.
How We Share Personal Information
We may disclose your personal information to third parties for business-related purposes. In the preceding twelve (12) months, we may have disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category I: Professional or employment-related information.
- Category J: Non-public education information.
Third Parties to Whom We Disclose Personal Information
We may disclose your personal information to the following categories of third parties:
- Third parties as part of our secondary market-related activities and other aspects of our business, including to loan servicers, attorneys, and technology providers who enable us or third parties to perform business, professional, and technical support functions for us or you. For example, third-party loan diligence providers who review and assess eligibility of your mortgage loan for purchase.
- Third parties who assist us with this website.
- Regulators, and as otherwise required by applicable laws, regulations and court orders.
In the last twelve (12) months, we have not sold any personal information other than as specified in this Policy.
This section describes certain rights of Consumers under the CCPA. For information on how Consumers may contact the Company to exercise these rights, please see the section below entitled, “How to Submit a Request.”
Right to Know
A Consumer has the right to request that a business disclose what personal information it collects, uses, discloses or sells. Specifically, a Consumer may request that a business that collects personal information about the Consumer disclose to the Consumer the following:
- The categories of personal information it has collected about that Consumer.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information it has collected about that Consumer.
A Consumer may request that a business that sells the Consumer’s personal information, or that discloses it for a business purpose, disclose to that Consumer:
- The categories of personal information that the business collected about the Consumer.
- The categories of personal information that the business sold about the Consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information that the business disclosed about the Consumer for a business purpose.
Please note that we may not disclose the information you have requested if we are unable to verify your identity. In addition, we may not disclose certain information that is covered by one or more of the exemptions from the CCPA, as outlined earlier in this Notice.
Right to Request Deletion
A Consumer has the right to request that a business delete any personal information about the Consumer which the business has collected from the Consumer. If it is necessary for the Company to maintain the personal information for certain purposes, the Company is not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.
How to Submit a Request
To exercise the rights described above, you must submit a verifiable Consumer request to us by contacting the Company and providing the requested information. You may submit a verifiable Consumer request through any of the following methods:
- By toll free telephone at 1-833-862-3863
- You may submit a request by email to email@example.com
You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period.
You may make a verifiable Consumer request on behalf of your minor child.
You may also designate an authorized agent to make a request on your behalf, but we will require that the authorized agent submit proof in the form of a written authorization from you that they have been authorized to act on your behalf.
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.
- If you are a borrower in connection with a loan owned by the Company, you must provide your full name, address of the property securing the loan, loan number, phone number and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- If you have submitted personal information to us through our website, you must provide your full name, the company on whose behalf you submitted a contact form to us, email address and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
A Consumer has the right not to be discriminated against because the Consumer exercised any of the Consumer’s rights under the CCPA. The Company may charge a Consumer a different price or rate, or provide a different level or quality of goods or services to the Consumer, if that difference is reasonably related to the value provided to the Consumer by the Consumer’s data.
Changes to This Policy
This Policy was last updated on January 1, 2020. We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will notify you by posting the updated Policy on our website homepage. Please be sure to check back periodically for any updates.
How to Contact Us
If you have any questions or comments about this Policy, please contact us at firstname.lastname@example.org.