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Federal Financial Privacy Notice

View our Privacy Policy Notice that discloses how we collect, share, and protect your personal information here :  https://www.cp-mtg.com/wp-content/uploads/2022/12/CPMS-Privacy-Policy-1.pdf

Information We Collect

The Site does not collect personally identifiable information about you unless you expressly provide such information, such as your name, physical address, and email address, to us on a voluntary basis, for example, when submitting a request for a callback or a complaint. We may also add the information you expressly provide to our databases or contact lists. We use such personally identifiable information to send you the information you request, to respond to your inquiries and comments, and, from time to time, to send you information regarding events and developments that Capital Partners Mortgage Services, LLC (CPMS) think may be of interest to you.

If you decide at any time that you no longer wish to receive information from CPMS, please see “Contact Us” below. On rare occasions, CPMS may send important administrative information regarding the Site or services to users using their email addresses; because such information may be important to your use of the Site, it may not be possible to “opt-out” of receiving such emails.

 

Cookies:

The Platform uses cookies, and similar technologies to cookies, to collect information about your access and use of the Platform. A number of cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to the Platform and will last for longer. You can also update your privacy settings on your device by setting the “Limit Ad Tracking” and Diagnostics and Usage setting property located in the settings screen of your Apple iPhone or iPad, or by resetting your Android ID through apps that are available in the Play Store. You can also stop information collection by uninstalling the App on your device and you can use the standard uninstall process available as part of your device for this purpose.

Non-personally Identifiable Information

We also automatically collect non-personally identifiable information through cookies and log files when you access the Site. Such information includes, without limitation, the following: your internet service provider, the IP address of the computer you are using, the type of browser software and operating system that you use, the date and time you access the Site, your length of stay on the Site, the pages that you visit on the Site, the Web site address, if any, from which you linked directly to the Site, the Web site address, if any, to which you travel from the Site, and other similar traffic information. We may aggregate your information with similar data collected from other users to help us improve our Site and the services we provide through our Site. We do not use such data in any way to create or maintain a personal profile of you or to collect personally identifiable information from you.

Our Use of Information We Collect

Generally, we do not disclose personally identifiable information that we collect through your use of the Site to unaffiliated third parties without your consent. However, we reserve the right to provide such information to our employees, contractors, agents, and designees to the extent necessary to enable them to perform certain Site-related services on our behalf. We also reserve the right to disclose such information to any third party if we believe that we are required to do so for any of all of the following reasons: (i) by law; (ii) to comply with legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Site or our network; or (iv) to protect the rights, property, or safety of CPMS and its employees, users of the Site, or the public.

Third parties may use cookies, web beacons, and similar technologies to collect or receive information from our website and elsewhere on the Internet and use that information to provide measurement services and target ads. You can opt-out of the collection and use of information for ad targeting by visiting www.aboutads.info/choices.

CPMS reserves the right to transfer any and all information we collect from users, or that we otherwise collect in connection with the Site, including, without limitation, to unaffiliated third parties, in the event of a sale or transfer of assets or portion of our business.

Security

CPMS employs industry-standard security measures designed to protect against the loss, misuse, or alteration of personally identifiable information under our control. Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. Therefore, while we employ industry-standard security measures to protect your personally identifiable information, we cannot guarantee the security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the site.

Links to Other Web Sites

The Site may contain links to Web sites owned by third parties. If you link to any such Web site, any information you disclose on that site is not subject to this Privacy Policy. You should consult the privacy policies of each Web site you visit. We are not responsible for the privacy practices of others. Any Site link to a Web site owned by a third party does not constitute an endorsement, approval, association, sponsorship, or affiliation with the linked site unless specifically stated.

Children Under 13

The Site is not directed to children under thirteen years of age, and we do not knowingly collect personally identifiable information from such children. If you are younger than thirteen, please do not provide any personally identifiable information while using the Site.

Changes to Privacy Policy

We reserve the right to update, revise or otherwise change this Privacy Policy at any time and any changes to the Privacy Policy will be effective upon posting. Your use of the Site constitutes your acceptance of the currently posted Privacy Policy, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.

Contact Us; Opt-Out

If you would like to update or otherwise change the personally identifiable information you have provided to us, or if you no longer wish to receive materials from us or want your personally identifiable information removed from our databases, please contact us at CPMS. Alternatively, if and when you receive materials from us by email, you may make use of the “opt-out” provision in such email to let us know that you no longer wish to receive such materials from us. If you have any questions about this Privacy Policy or our collection and use of your personally identifiable information, please contact us at CPMS

Review/Update  12/12/2022

 

 

CALIFORNIA CONSUMER PRIVACY (CCPA) ACT NOTICE

 

Capital Partners Mortgage Services, LLC (“CPMS” or “us” or “we”) is committed to protecting the privacy and security of the personal information it collects. This Privacy Notice for California Residents (“Privacy Notice”) supplements Privacy Policy Notice found here: https://www.cp-mtg.com/wp-content/uploads/2022/12/CPMS-Privacy-Policy-1.pdf  and only applies to residents of the State of California (“consumers,” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

Introduction

Under the CCPA, “personal information” means 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, or household.  This Privacy Notice explains how we collect, use, and share your personal information. It also describes your privacy rights and our obligations under the CCPA regarding your personal information. However, please note that your privacy rights and our obligations described herein do not apply to certain personal information. For example, your privacy rights and our obligations noted in this Privacy Policy do not apply to personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”) and its implementing regulations. Please see CPMS’ Privacy Policy to find out how we collect, share, and protect information covered under GLBA.

Information We Collect

We collect information that identifies, relates to, describes, and references is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Category Examples
 

Identifiers

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

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

Name, signature, Social Security Number, address, telephone number, passport number, driver’s license or state identification card number, date of birth, education, employment, employment history, tax returns, income, credit history, credit scores, payment history, retirement account balance, retirement account number, checking and savings account balance, bank account number, credit card number, debit card number, or any other financial information.

 

Some personal information included in this category may overlap with other categories.

Protected classification characteristics under California or federal law. Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.
Commercial information Records of personal property, assets, rental history, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Professional or employment-related information. Work history and/or employer’s information
Internet or other similar network activity Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement.
Sensory data Audio, electronic, visual, or similar information
Biometric information Keystroke
Geolocation data Physical location or movements
Inferences are drawn from the above-listed personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

 

Personal information does not include:

 

  • Publicly available information from government
  • De-identified or aggregated consumer
  • Information excluded from the CCPA’s scope, like:
    • 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 is covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

We obtain the categories of personal information listed above from the following categories of sources:

 

  • Directly from our clients or their For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their For example, through information, we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our website (www.apmortgage.com). For example, submissions through our website portal or website usage details are collected automatically.
  • From third parties that interact with us in connection with the services we perform. For example, from government agencies when we verify certain identify information or tax-related information.

 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

 

  • Performing services, including offering, processing, underwriting, making, or servicing residential mortgage loans.
  • Developing and carrying out marketing activities
  • Providing customer support and managing our relationship with you
  • Creating, maintaining, and securing your loan account
  • Auditing or quality control
  • Complying with applicable law, agency requirements or investor requirements
  • To improve our website and present its contents to
  • When or if applicable, to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sale of Personal information

We do not sell, will not sell, and have not sold in the past 12 months, personal information to third parties, including personal information of minors under the age 16.

Sharing Personal Information

We may disclose your personal information to a third party for business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

 

We disclose your personal information for a business purpose to the following categories of third parties:

 

  • Our affiliates, if
  • Service
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

 

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about
  • The categories of sources for the personal information we collected about
  • Our business or commercial purpose for collecting or selling that personal
  • The categories of third parties with whom we share that personal
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

 

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Comply with federal laws that require us to retain data and records for a minimum period.
  3. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  4. Debug products to identify and repair errors that impair existing intended
  5. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  6. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code
  • 1546 seq.).
  1. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
  2. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  3. Comply with a legal
  4. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

 

  • Calling us at 844-722-7672
  • Emailing us at contactus@cp-mtg.com

 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will work to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

 

  • Deny you goods or
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices, and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 844-722-7672

Website: www.c-mtg.com

Email: contactus@cp-mtg.com

Postal Address: 2121 SW 3rd Avenue

Suite 101

Miami, FL  33129

 

REVIEW/UPDATE:  12/12/2022

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