II. The Kinds of Information We Collect
A. Information You Provide
We ask you to provide information that we need to evaluate whether you qualify for a mortgage and are satisfied with our services, such as:
- Your name and contact information;
- Bank account, income and employment information;
- Details about your current home, mortgage and other liabilities;
- Your driver’s license or state ID information;
- Real estate offer letters;
- Citizenship status (for tax calculation purposes);
- Marital status (for tax calculation purposes);
- Your Social Security number; and
- Reviews or comments you leave about our Services.
B. Information We Collect From Your Device(s)
We may collect the following information from the device that you use to access our Services:
- Device attributes such as the operating system, hardware and software versions, and browser type;
- Information you allow us to receive through device settings you turn on, such as access to your GPS location;
- Network and connection information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, and IP address;
- Data from cookies, tags, pixels, web beacons, and log files stored on your device. Please note our Services do not support Do Not Track signals from your browser.
We generally use this information for your convenience and to improve our Services. For instance, we may use it to: (i) remember your information so that you do not have to re-enter it; (ii) provide you with customized content and information, including advertising; (iii) monitor the effectiveness of our Services; (iv) monitor aggregate metrics such as traffic and usage patterns; and (v) diagnose or fix technology problems.
C. Information We Collect When You Call Us
We may record telephone calls between you and our customer service team. We do this to make sure we provide you with the best possible service. Our customer service team members also enter certain information you provide into our customer service databases to ensure continuity and consistency throughout your experience with Tomo.
D. Information We Collect from Partners, Service Providers, and Affiliated Businesses
We may collect information about you from our service providers if necessary to provide our Services to you, such as to determine your eligibility for a mortgage.
III. How We Use This Information
A. To Provide Our Services to You
We use the information that we collect about you to deliver our Services, including to personalize features and content to you. As discussed in more detail below, you have choices about how and whether we process some of your information.
B. To Advertise Our Services
We may use information collected about you to provide you with relevant information about services that Tomo offers.
C. To Do Market Research
We are constantly striving to improve our customer experience. We conduct research into all aspects of the home financing process to try to identify ways to make it better. We also aggregate and analyze consumer information that we collect on our website and from conversations with our customer service representatives to identify trends which inform how we change and grow. We only use this information for internal purposes.
D. To Support Information Security and Debugging
We may use information about you and your use of the Services to detect security incidents, protect against malicious, fraudulent, or illegal activity, and improve the security and operation of our systems.
E. In Connection with a Dispute
We may use personal information to prosecute or defend against claims in court and other dispute resolution forums.
IV. Why and How We Share Your Information
A. With Your Consent
We may share your information when you specifically direct us to do so.
B. With Service Providers Who Facilitate Our Ability To Provide You With The Services
We may share your information with service providers to the extent necessary to provide the Services to you, such as to procure consumer reports and verify your employment, income and assets.
C. With Law Enforcement, Courts, or Government Agencies
We may share your information as necessary to respond to legal process or to regulatory authorities (such as pursuant to a subpoena, warrant, investigative demand from law enforcement, regulators, or others; national or international security letters; etc.); to investigate, prevent, or take action regarding suspected or actual illegal activities (including fraud) and security or technical issues; to respond to or participate in commercial disputes (e.g., lawsuits or investigations); or to protect against fraud, claims, or other liability or harm to you, us, or others.
V. When Third Parties Benefit from Tomo Sharing Your Information with Them
A. "Selling" Your Data
Tomo is not a data broker. We do not sell your information to third parties, and, except for sharing general loan application status updates with your real estate agent, Tomo will not share any of your information with third parties. If you do not want us to share updates with your real estate agent, you can opt-out by talking to your Loan Advisor.
VI. How We Protect Your Information
We use commercially reasonable physical, electronic, administrative, and procedural safeguards to preserve the integrity, confidentiality, and security of all personal information collected through the Services. However, no security measure, system, or control is infallible. Therefore, like all businesses, we cannot guarantee that our systems are invulnerable to attack or misuse.
B. Your Role
You have a major role in the security and privacy of your own information. For example, you should not provide us with personal information that we do not request. Additionally, you are responsible for controlling access to any personal computing device through which your information may be stored or accessed. You are also responsible for safeguarding any passwords or other log-in credentials that may be used to access your information, including in the Tomo environment. We recommend that you log out of any account when you are done using it.
C. Third Parties
Please remember to review the privacy settings and security policies of third-party sites and services that you use, such as social networks. We are not responsible for the privacy or security measures of any third party.
D. Incident Response
In the event that the security of any personal information under our control is compromised, we will take reasonable steps to investigate and mitigate the situation, including, when appropriate, notifying those individuals whose information may have been compromised and taking other steps in accordance with applicable laws and regulations.
VII. Your Rights and How To Exercise Them
A. Right to Opt-Out of Sales of Your Personal Information
Tomo does not sell your personal information. You may contact us at email@example.com if you have any questions about this or wish to exercise any of your opt-out rights. We will respond in less than thirty days.
B. Right to Know About the Personal Information We Collect and Share
You have the right to request that we tell you about our collection, use, and sharing of your personal information over the past twelve months. Once we receive and validate your request, we may disclose to you:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purposes for collecting that personal information;
- The categories of third parties with whom we share that personal information;
- The specific pieces of personal information we collected about you (also called a data portability request); and
- The categories of personal information about you that we disclosed to third parties for a business purpose and the categories of recipients of that information.
C. Right to Delete the Personal Information We Collect and Share
You have the right to request that we delete your personal information, subject to certain exceptions. Depending on the nature of the data, deletion may consist of erasing, aggregating, or anonymizing your information. After we receive and validate your request, we will delete and direct our service providers to delete your personal information, unless an exception applies. We may deny your deletion request, in whole or in part, if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a 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;
- Comply with the recordkeeping requirements of applicable mortgage laws and regulations;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug to identify and repair errors that impair existing intended functionality;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; or
- Comply with a legal obligation or make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Please be aware that, once deleted, your data, including your account and activities, cannot be restored.
D. How to Make a Request to Know or Delete
You may, without charge, request to know or delete your personal information by contacting firstname.lastname@example.org. Only you or an authorized agent may make a request to access your personal information. You have the right to make a free request twice during any twelve-month period. The request must:
- Provide sufficient information for us to reasonably verify that you are the person, or an authorized representative of the person, about whom we collected the personal information; and
- Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.
For your safety and the safety of your information, we cannot fulfill a request to provide or delete personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or an individual for whom you are a lawful agent. We may require additional verification before deleting or disclosing particularly sensitive information. We will only use the verification information you provide for the purpose of verifying your identity or authority to make the request.
Submitting a request does not require you to create an account with us.
We do not charge you 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.
VIII. Children's Privacy
Our website and services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under the age of 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us, and we will take steps to delete such information from our records.
We will not discriminate against you for exercising any of your rights under Section VII. Unless permitted by law, we will not:
- Deny you goods or services;
- 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 of quality of goods or services; 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.