Privacy & CCPA

Privacy Policy

Willow Bend Mortgage, LLC (WBM), values your business and protecting your confidential information is important. Our policies and procedures reinforce the fact that WBM strongly believes in protecting the confidentiality and security of the information we collect about you as a customer through the lending process. We have adopted the following policies and procedures that apply to safeguard all personal information in our possession.

Introduction

This policy is a summary of our internal policy that discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. It addresses how personally identifiable information that we may request will be used. We also detail below our security policy which describes how your personal information is protected both electronically and physically.

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 to fulfill transactional needs.
Our policy requires 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 procedures for controlling access to customer files, building security and information technology security measures such as the use of passwords, firewalls, virus prevention and use detection software.
We continue to assess the effectiveness of technologies used in the loan origination process.
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, 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.

Security Policy Statement

Willow Bend Mortgage, LLC takes concrete steps to safeguard your personal and sensitive information through standards addressing physical, electronic and operational policies, procedures and practices. All data that is considered confidential and can only be read or written through defined service access points with password-protection with restricted access for staff with a need to know and need to do permissions. Physical security of all data is achieved through a combination of networks, firewalls and servers in a secure facility. Systems are periodically tested for resilience and continuity. Access to systems and applications, both physical and electronic, are controlled through a role based access framework.

Information We Collect About You

We collect information about you to help us serve your mortgage loan financial needs consistent with regulatory and investor requirements. We consider non-public information about you in our possession to be personally identifiable information, even if you cease to be a customer. The personally identifiable information we collect about you may include:

Maintaining regular communications with you as may be necessary to obtain and process your loan application, supporting information such as identity verification, income verification and employment verification and information to perfect loan security interest.
Contacting you through the loan process to reconcile information and address problems completing a transaction you requested.
Our policy requires all employees to safeguard personally identifiable information about the 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 loan origination process. 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.
We collect non-identifying personal 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 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 your services. We will retain and use your information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

Communications from Our Site, Including Sites of Our Affiliates

When you complete an application on our site you will receive emails that confirm specific actions you requested. You will receive notifications confirming receipt of your application, loan disclosures outlining cost of your loan request and confirmations of successful submissions of required documentation needed to process your loan. 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 will respond to emails you send us, if appropriate or applicable. We may 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 or unsubscribe in any offer email you receive from us.

Our affiliates are disclosed to you and are used to expedite loan transaction requests and are covered under the same umbrella Privacy and Security policy. You are not required to use them.

A listing of our affiliates follow:

Capital Title of Texas, LLC
Premier Surveying, LLC
Cambridge Insurance Agency, LLC
United Tax Service

Links to Third Party Websites

WBM 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 WBM (“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 WBM 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

WBM may display personal testimonials of satisfied customers on our sites in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at marketing@wbm.com.

Notifications

WBM will send you email notifications during the loan process that 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 initial terms, conditions and costs of your loan transaction and any change in status thereafter or when you are confirmed as a borrower or for legal purposes. Notifications involve changes to various legal agreements, loan disclosures, 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 WBM

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, and sale of your loan. These third parties include among others, title companies, credit reporting agencies, 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

For some of our online services, you can review and update certain account information by logging in and accessing your user profile on our website. If you cannot change your information online, or you prefer to request changes offline, please contact your Loan Officer or representative listed on our correspondence or other account materials sent to you.

Web-related Information Collection

WBM website does not collect and retain your personal information. Input forms are used to pass through information that allow users to submit questions or concerns to WBM for response. We use Web analytics tools that track website activity using meta data information that are non-personal in nature that track activity geographically, by time and type of web-browsers used. We do not internally employ the use cookies to track user activities beyond the contact with our website.

Analytic tools 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 the proper functioning of our site in terms of navigation and usability. At no time do any of our cookies capture any personally identifiable information and are not designed to capture personal identifiable information.

This site uses the Google Tools 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 WBM 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. As noted above, 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)

If you are a California resident, you may be entitled to additional rights over your personal information. For more information about these rights and how to exercise them, please CLICK HERE to see our California privacy policy.

Children’s Online Privacy Protection Act

WBM does not knowingly collect or solicit any information from anyone under the age of 13. We do not knowingly allow minors under the age of 13 to disclose their personal information to us through our sites or otherwise. Our websites are directed to individuals who are permitted to share their personal information without parental consent. If you believe that we may have any information from a child under the age of 13, please contact us at compliance@wbm.com or by phone at (972) 818-1666 and ask for the Compliance or Marketing Department.

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.

Links to Other Sites

We use links to loan fullfilment partner sites. We make the decision to integrate third party service links to sites based on the quality and effectiveness of services provided. These links are seamless that are enabled or to facilitate our customers’ more effective use of our products and services. These partners are contractually obligated to adopt our privacy policy and we make every effort to monitor the continuing quality and compliance of these relationships.

WBM’s servers operated using Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our website and production applications you are actually on our site. We exchange information from this SSL protocol to ensure that all data entered, exchanged, and maintained is only between you and WBM and not over the open internet. It is important to use the tools provided so we can control your privacy throughout the loan process. Sending sensitive information over the internet via PDF, jpegs or other formats is not advised and we cannot guarantee security. 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.

Session time-outs

We employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

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 WBM 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. WBM will never ask for login information to gain access to customer’s account and access sensitive information. WBM 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 either opting out or unsubscribing from these communication methods or contacting us at phone number (972) 818-1666. 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.

Our Do Not Call policy states that you may instruct us not to call you for marketing purposes by informing us at phone number (972) 818-1666. 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.

Contacting Us

If you have any questions about this privacy policy, please write us at:

WBM, LLC
5880 W Plano Parkway Suite 105, Plano, TX 75093
compliance@wbm.com

Privacy Policy for California Residents

This PRIVACY POLICY FOR CALIFORNIA RESIDENTS supplements the information in our privacy notice and applies solely to California residents (“California Consumer” or “you”). A business that collects a California consumer’s personal information must inform consumers as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”), Cal. Civ Code § 1798.100 et. seq., have the same meaning when used in this notice.

Under CCPA, California residents have the right to know about information collected disclosed or sold, the right to opt out of the sale of certain information, and a limited right to have businesses delete information a business has collected about the consumer. These rights extend only to California residents and information covered by CCPA. Because CCPA does not cover all consumer data in all situations, only certain consumer data subject to these rights.

Other laws may govern data we gather about you or you provide to us including, but not limited to:

Information to or from a consumer reporting agency if that information is to be reported in, or used to generate, a consumer report as defined by subdivision (d) of Section 1681a of Title 15 of the United States Code, and use of that information is limited by the federal Fair Credit Reporting Act (15 U.S.C. Sec. 1681 et seq.)
Information collected, processed, sold, or disclosed pursuant to the federal Gramm–Leach–Bliley Act (Public Law 106–102), and implementing regulations, or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code).
- PLEASE NOTE: Any personal data collected in relation to a mortgage loan transaction is exempt from the consumer right to know, delete and opt-out created under CCPA because this information is governed by the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, the California Financial Information Privacy Act or other state and federal laws which exempt this data from CCPA.

Information We Collect
Willow Bend Mortgage, LLC, as “Company” or “we” or “us”) collects 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”). As described above, not all of the Personal Information collected below is subject to CCPA. All Personal Information collected pursuant to this notice that is subject to CCPA is collected for a Business Purpose and may be shared with service providers if necessary, to perform a Business Purpose. We may have collected the following categories of personal information from consumers within the last 12 months:

Category Examples

Does the Company collect this Category of Information?
Categories of Sources from which the Information was Collected
Business Purpose

Categories of third parties with whom the business shares this information

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
YES

Consumer Directly
Mortgage loan origination and related services. Related services may include, but are not limited to real estate services, insurance, escrow and other closing services, notary, appraisal, other consumer credit services, home warranty, and other services related to home purchase, home ownership, or related consumer transactions.

While we do not sell your data, we may share that data with our joint marketing partners which include affiliates, financial services providers, realtors, builders and other residential real estate companies. This sharing is done pursuant to federal law and is exempt from the California state requirements under CCPA.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A 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, any other financial information, or medical information. Some personal information included in this category may overlap with other categories.
YES

While we do not sell your data, we may share that data with our joint marketing partners which include affiliates, credit card companies, financial services providers, realtors, builders and other residential real estate companies. This sharing is done pursuant to federal law and is exempt from the California state requirements under CCPA.

C. Protected classification characteristics under California or federal law

Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, , veteran or military status, 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.
YES

Consumer Directly, Government Entities
Mortgage loan origination and related services. Related services may include, but are not limited to real estate services, insurance, escrow and other closing services, notary, appraisal, other consumer credit services, home warranty, and other services related to home purchase, home ownership, or related consumer transactions.

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, gait, or other physical patterns, and sleep, health, or exercise data.
NO

Mortgage loan origination and related services. Related services may include, but are not limited to real estate services, insurance, escrow and other closing services, notary, appraisal, other consumer credit services, home warranty, and other services related to home purchase, home ownership, or related consumer transactions.

F. Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES

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 or performance evaluations.
YES

While we do not sell your data, we may share that data with our joint marketing partners which include affiliates, financial services providers, realtors and builders. This sharing is done pursuant to federal law and is exempt from the California state requirements under CCPA.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
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

Consumer Directly, Government Entities,
Mortgage loan origination and related services. Related services may include, but are not limited to real estate services, insurance, escrow and other closing services, notary, appraisal, other consumer credit services, home warranty, and other services related to home purchase, home ownership, or related consumer transactions.

K. Inferences drawn from other personal information
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
NO

Rights under CCPA

Right to Know About Personal Information Collected, Disclosed, or Sold. California consumers have the right to request that a business disclose what personal information it collects, uses, discloses, and sells.

Right to Request Deletion of Personal Information. Under CCPA, you may have the right to request the deletion of your personal information collected or maintained by the Company.

Right to Opt-Out of the Sale of Personal Information. Under CCPA, you may have the right to opt-out of the sale of their personal information by a business. Note that as defined in CCPA, the Company does not, and will not, sell your personal information.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. Under CCPA, you have the right not to receive discriminatory treatment by the Company for the exercise of the privacy rights conferred by the CCPA.

Instructions for Submitting a Verifiable Consumer Request to Know, Delete, or Opt-Out

For a request to be acknowledged, you must either fill out and submit the online form on our “Contact Us” page or email us at Compliance@wbm.com call our toll-free number at phone number 972-818-1666. After submitting a request, we will verify your identity by matching the identifying information provided by you to the personal information already maintained by us, or, in cases where your request requires a higher degree of certainty, we may use a third-party identity verification service or ask for a photo ID or for more information. Any information you provide us that is not already in our system will be deleted after your request has been fulfilled.

Authorized Agents

You may use an authorized agent to submit a request to know or a request to delete. If you use an authorized agent to submit a request to know or a request to delete, you must provide the Company with written permission from you giving the authorized agent permission to submit the request on your behalf, and you may be required to verify the authorized agent’s identity with the Company. The Company may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

Additional Information

For more information about our general privacy policy, please visit https://www.wbm.com/privacy or email us at compliance compliance@wbm.com with questions or concerns about our privacy policies and practices.