Additional Notice for California Residents

This section of our Privacy Notice applies to residents of California.

Personal Information about California Consumers

The information we have collected from California consumers in the previous twelve months consists of the information listed below and in the information outlined in our Privacy Policy.

  • Identifiers, which include name, postal address, email address, social security number, bank account data and other financial identifiers, unique personal identifiers, online identifiers, IP address, and other similar identifiers. We collect identifiers such as name, address and contact information in order to provide you with our Products and Services. We may collect your IP address and unique device identifiers when you visit our websites. We may also receive information about a disability, where relevant to the Services we provide, such as when a custodian is acting on your behalf.
  • The following categories of personal information described in California Civil Code §1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” (2) signature, (3) telephone number, (4) payment information (including payment card details or online payment services number and invoicing address) and financial information, and (5) the other information that identifies, relates to, describes, or is capable of being associated with, a particular individual.
  • Protected classification characteristics under California or federal law (for example, race, marital status, disability status, and ancestry).
  • Commercial information about your transactions and experiences with us and others, including loan status and payment history.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with the Site and mobile application, and advertisements that we display on the Site or mobile applications or on third party sites and mobile applications.
  • Audio information from calls made to us, which may be recorded, and electronic information in the form of Internet or other electronic network activity information as described above.
  • Professional or employment-related information, in the form of business contact information. We may also obtain information such as education or employment history from credit bureaus, which we use to help prevent and detect fraud and to offer certain services.
  • Inferences drawn from (1) the information we collect when you visit our websites, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumer preferences and behavior that we collect on our websites or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, behavior, and attitudes.

We collect the above personal information directly from consumers, as well as from other sources, including credit bureaus, fraud-detection services, public databases, social media platforms, and third-party partners such as analytics or marketing providers. For more information on sources from which we collect information, please see our Privacy Policy.

We use personal information in the above categories for the business purposes listed in our Privacy Policy and the following business purposes:

  • To provide information and respond to your requests
  • For our core business purposes, such as providing quotes for loans, processing applications, establishing and servicing your mortgage, responding to your inquiries and providing customer support
  • To operate, evaluate and improve our business, including developing new products and services, and analyzing and enhancing our products, services and websites
  • To perform data analyses (including market and consumer search and analytics, trend analysis and profiling, financial analysis and anonymization of personal information)
  • To protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities
  • To comply with applicable legal requirements and our policies
  • To establish, exercise and defend legal claims
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity
  • To maintain and enhance the security of our systems and data
  • To conduct marketing activities and communicate with you regarding products and services of Smartfi Home Loans and our partners that we think may interest you
  • To undertake internal research for technological development
  • To deliver website and mobile app content (including advertising) based on your interests and browsing history
  • To enable you to interact with us through social media platforms
  • For other purposes permitted by law or to which you consent

We disclose the above categories of personal information for the business purposes identified above to affiliates, service providers in connection with their provision of services to us, and as described in our Privacy Policy. In addition, we may disclose information (i) when required by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, or (iii) when necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; and (iv) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Sales of Personal Information

We do not sell your information.

Your California Privacy Rights

If you are a California resident, you have the following rights:

(1) The Right to Know. You have the right to request that we disclose to you the categories and specific pieces of information we have collected about you. Specifically, you have the right to request that we disclose of what personal information we collect, use, and disclose, including:

  • Specific pieces of information that we have collected about you
  • Categories of personal information we have collected about you
  • Categories of sources from which the personal information is collected
  • Categories of personal information about you that we sold or disclosed for a business purpose;
  • Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • The business or commercial purpose for collecting personal information.

(2) The Right to Deletion. You have the right to request that we delete the personal information that we have collected about you.

Verification Process

For requests made in connection with the Right to Know or Right to Delete, as required under applicable law, we must take steps to verify your request before we can provide personal information to you, delete personal information, or otherwise process your requests. We may limit our response to your exercise of the above rights as permitted by law.

Authorized Agents

You may designate an authorized agent to make a request on your behalf. An agent may be an individual, or a business entity registered with the California Secretary of State. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to verify your identity directly (subject to certain exceptions). We may refuse a request if the agent does not provide adequate proof of their authorization.

Even if you choose to use an agent, we may, as permitted by law, require:

  • The authorized agent to provide proof that the consumer gave the authorized agent signed permission to submit the request;
  • The consumer to verify their identity directly with the business;
  • The consumer to directly confirm with us that they provided the authorized agent permission to submit the request.

Non-Discrimination

We may not discriminate against you for exercising any of your rights under the CCPA. This means that we may not deny you services, charge you different prices or rates for services, provide you with a different level or quality of services, or suggest that we will do so in response to a request made under the CCPA. However, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.

How to Exercise These Rights

You may request to exercise the foregoing rights by:

Calling us toll-free at (877) 607-8815;
Emailing us at connect@smartfihomeloans.com, or
Mail your request to: Smartfi Home Loans, LLC, 3636 Nobel Dr., Ste 210, San Diego, CA 92122, Attention: California Privacy/Compliance

Alternative Format

This policy can be accessed in an alternative format by contacting us at compliance@smartfihomeloans.com.