Last Revised: July 25, 2024

Summary: We do not sell or share personally identifiable information (PII) of consumers, applicants or borrowers for marketing purposes, and we will not do so in the future unless we first ask for and obtain your verifiable consent. We do not collect any PII of children or teenagers or health-related PII, because our only business is HECM or reverse mortgage lending. To be eligible for a HECM loan, the borrower must be at least 62 years of age. We acquire PII of potential HECM borrowers from consumer data resellers, credit reporting agencies, government agencies, public records, and other sources, and we use that information to market HECM loans to potential borrowers in accordance with applicable law. We promptly honor do-not-contact requests. We also take measures to help protect PII in our control from misuse or unauthorized access (see Data Security, below).

Overview: We are Traditional Mortgage Acceptance Corporation, a Maryland corporation, doing business under our registered mark GoodLife Home Loans® (“us” or “GoodLife”). We respect your privacy, and we try to comply with all applicable laws relating to consumer privacy and data security laws. Our privacy practices are based on the fundamental principles of notice, choice, accuracy, data minimization, and limited disclosure. Read on for the details about how GoodLife handles personal data.

Personally Identifiable Information. Personally identifiable information (“PII”) is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. PII does not include information that has been effectively aggregated or de-identified.

No Sales of PII: We do not sell PII for monetary compensation, and we will not do so in the future unless we first ask for and obtain your verifiable consent. We do share PII with service providers for purposes of targeted advertising and marketing of our own goods and services. However, you may stop marketing communications from us at any time (Marketing Communications, below).

Application: This Online Privacy Policy is our representation and notice to you regarding our information privacy practices and your rights. It applies to all PII and other personal information obtained by us, from all sources and in all media, including through our website GoodLifeHomeLoans.com (the “Site”). This Privacy Policy explains:

• what categories of information we collect and from where;
• how we use the information;
• with whom we may share the information;
• what choices you have about our collection, use and disclosure of the information;
• what security procedures are in place to protect against the loss, misuse or alteration of information under our control; and
• how you can correct any inaccuracies in the information.

When you visit the Site, we collect information in these categories:

• Identifiers – We collect PII, such as your first and last name and email address. We may ask for your name, mailing address, email address, phone number and age. We may ask you to create a username and password linked to your PII. If you ask us to verify your eligibility for an HECM loan from GoodLife, we will collect and store additional PII, including your social security number and additional financial information as listed below. We will also collect and store PII provided to us about any potential co-borrowers.
• Financial –We collect financial information necessary to decide eligibility for a GoodLife HECM loan, to process an application for a GoodLife HECM loan, or to provide services related to an approved GoodLife HECM loan. This information included income, account balances, payment history, credit scores and related financial data.
• Online Activity – We may collect information about your device such as its IP address, MAC address, and associated advertising identifier (such as IDFA or AAID). If permitted, we may collect PII related to your online activity, such as your browsing history. This Privacy Policy describes some ways to limit this type of collection.
• Geolocation – We may collect PII about the location of your device, but you can limit our ability to collect this information.
• Likeness & Biometrics – We may collect biometric PII such as your image or likeness, for example if we verify your identity using official documents such as a driver’s license or passport. With notice and your consent, we may record voice or video calls with us, for quality assurance.
• Content – We collect the content of messages sent to us, our loan officers and customer service representatives.
• Inferences – We may draw inferences from the PII and other information described above, such as inferences about the identity of the user of a particular device.
• Sensitive Information – If we collect sensitive PII, we will use it only for the intended purpose and strictly limit its disclosure. Sensitive PII includes data about racial/ethnic origin, religious beliefs, health conditions or diagnoses, alternative gender identity or sexual orientation, citizenship or immigration status, consumer health data, genetic or biometric data, or precise geolocation data. We do not ask Site visitors for PII about their racial/ethnic origins, religious beliefs, health conditions or diagnoses, gender identity or sexual orientation.

Updates & Changes: We may update or modify this Privacy Policy from time to time, and we will post the changes here. If we change this Privacy Policy in a way that materially alters your rights, we will provide notice to your last-known email address, and an opportunity to exercise your rights. If state law or other applicable law gives you additional rights in these circumstances, we will follow the applicable law (Rights under State Law, below).

Sources of PII

PII We Collect Directly from You: If you contact us, through our Site or by phone or other means, we will collect your PII including your name, mailing address, email address, phone number and age. If you ask us to verify your eligibility for an HECM loan from GoodLife, we will collect and store additional PII including your home address, social security number, income, account balances and payment history, credit history, credit scores and related information about your home. We will also collect and store PII provided to us about any potential co-borrowers.

PII We Collect Indirectly: We obtain PII of potential HECM borrowers from third parties such as consumer data resellers, credit reporting agencies, government agencies, public records and other sources. If we have contacted you as the result of our obtaining your PII indirectly, and you do not want to be contacted by GoodLife, we will promptly honor your do-not-contact request. If you submit a complete application for a GoodLife HECM loan, we will obtain your credit report from one or more credit reporting agencies to aid us in determining your eligibility for the loan.

Other Information We Collect (Not PII): Our Site use server logs to collect information that is not by itself personally identifiable (such as browser type, ISP, IP address, referring/exit pages, platform type, date/time stamp, and number of clicks) from all visitors to the Site. Our Site also uses “cookies” to collect information about how the Site is used. Information gathered through cookies may include the pages viewed and the amount of time spent at the Site. Our Site use both session ID cookies and persistent cookies. The session ID cookie terminates once you close the browser. For the persistent cookie, a text file is stored on your computer. Persistent cookies can be removed by following Internet browser help file directions. If you allow the persistent cookie, our Site can recognize your computer and apply your preferences for our Site. If you reject the cookie, your user experience may be limited. We may use web beacons and similar technologies to track your use of our Site. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. We also may include web beacons in email messages or newsletters to determine whether messages have been opened and acted upon. We use information that is not by itself personally identifiable to improve our Site, reconstruct activity from a session or by a user, and for troubleshooting. Our Site does not recognize browser do-not-track settings. If we combine your PII with information that is not by itself personally identifiable, we will treat the combined result as PII.

PII From Social Media: We may use social media websites or messaging applications to interact with you and to communicate information about GoodLife products and services. We may collect PII from our interactions with you on social media websites and applications, and we may use this PII for the purposes and uses described in this Policy.

Our Uses of Your PII

Marketing Communications: We may send you notices about GoodLife products or services. You may withdraw your permission to receive marketing communications from us at any time. You can opt out by following the instructions at the bottom of any GoodLife marketing email or flyer, calling our toll-free number at 866-839-9342, emailing to info@GoodLifeHomeLoans.com or clicking here.

Service Communications: If you express interest in or apply for a GoodLife HECM loan, we will communicate with you about the application process and other aspects of the loan. You may not opt out of these service-related communications, but you may terminate your application process at any time and opt out of further communications from us.

Evaluation of Eligibility and Loan Applications: If you express interest in or apply for a GoodLife HECM loan, we will use your PII to evaluate your eligibility to apply for and receive the loan.

Loan Servicing and Customer Relations: If you receive an HECM loan from GoodLife, we will use your PII to respond to your inquiries and requests, to send you notifications, to manage our relationship with you, to provide you with customer support and to service the loan.

Internal Business Uses: We may use your PII for our internal business purposes, such as:

• To analyze your use of, or interest in, our services;
• To measure the overall effectiveness of our advertising and content; and
• For data analysis, audits, fraud monitoring or prevention, and new product development.

Our Limited Disclosures of Your PII

GoodLife may disclose your PII as follows:

To Investors: If you have a closed HECM loan from us, we may share the loan-related PII with our affiliate and with third party investors to whom we may transfer your loan after closing. The potential investors are obligated to use your PII only as needed to evaluate the loan.

To Settlement Service Providers: If you apply for a GoodLife HECM loan, we will share your personal information with professional settlement service providers that perform services on our behalf. These settlement service providers include credit bureaus, title companies, flood or other insurance companies, appraisal companies, escrow companies, and closing agents. The settlement service providers are obligated to use your PII only as needed to perform their functions in connection with your request for a loan.

As Required By Law or Legal Process: We may disclose your PII in response to a lawful subpoena, court order or request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe is required by law. In such cases, we may raise or waive any legal objection or right available to us.

To Protect Our Business: We may disclose your PII when we reasonably believe disclosure is necessary to investigate or prevent actual or suspected unlawful activity; to protect and defend the rights, property or safety of our company, employees, customers or others; or to enforce our Site’s Terms or Service or other agreements between us and you.

Business Transition: If GoodLife goes through a business transition, such as a merger, being acquired by another company, or sale of its assets, PII held by us will, in most instances, be part of the assets transferred.

Accuracy and Maintenance of Your PII

Accuracy: We will strive to ensure that your PII held by us, if any, is accurate. You will have multiple opportunities to review, update and correct your PII during the loan proposal and application processes. You may also contact us to inquire about or correct the accuracy of your records: call us toll-free at 866-839-9342, email to info@GoodLifeHomeLoans.com or click here.

Maintenance: Although we promptly honor do-not-contact requests, we cannot offer you an unqualified right to delete your PII held by us. Federal and state laws, rules and regulations require that we store information collected for various periods of time. In order to comply with these requirements, we may be unable to delete your information entirely until the expiration of the applicable period. See Rights under State Law, below.

Data Security: We take reasonable precautions in accordance with industry standards to protect PII held by us from unauthorized access. We restrict access to your personal and account information, and we employ information security safeguards allowing employees and settlement service providers with proper authorization to access such information. We use firewalls and other intrusion detection and prevention controls to help prevent unauthorized persons from gaining access to your PII. We also use administrative and physical security measures. These measures include secured files and buildings. Security measures are by their nature not a perfect or complete defense against malicious actors. Accordingly, we cannot guarantee that your personal information will be completely secured against unauthorized access.

Data Breach Notification: GoodLife maintains procedures for notifying you in the event of a data security breach. If GoodLife experiences a data security breach and is required to notify you under applicable law, GoodLife will notify you by electronic mail using the e-mail address you have provided. You are responsible for ensuring that your contact information is current and correct. To review or change your information and correct any inaccuracies, call us toll-free at 866-839-9342, email to info@GoodLifeHomeLoans.com or click here.

Sensitive Information

No PII of Children: We do not collect any PII of children or teenagers because our only business is HECM lending, and HECM borrowers are all older than 62 years of age.

Limited Medical Information: Medical examinations and health tests are not required for HECM borrowers. When you apply for an HECM loan from GoodLife, we will not ask you for medical or health-related information. If we acquire such information, we will treat it as sensitive, and not use or disclose it for marketing purposes.

Procedures

Questions about this Policy: If you have questions about this Policy, our information practices or other aspects of privacy on our Sites, please call us toll-free at 866-839-9342, email us at info@GoodLifeHomeLoans.com, or send us a letter at GoodLife Home Loans, Attention: Customer Relations, 2558 Roosevelt Street, Suite 200B, Carlsbad, CA 92008.

Rights under Applicable State Law

 If your state has adopted a law granting you additional rights relating to PII collected by us, and the state law applies to us, we will comply with the state law. As of July, 2024, eight US states had currently effective and potentially applicable laws of this type: California, Colorado, Connecticut, Florida, Oregon, Texas, Utah, Virginia. A number of other states had potentially applicable laws scheduled to take effect within the next year. Applicable state law may give you some or all of these rights: to request additional information from us regarding our collection and use of PII, to ask us to correct or delete your PII, to direct us not to sell your PII, to limit our use and disclosure of sensitive PII, to appeal any denial by us of your request to exercise rights under state law, and to opt out of the use of your PII for automated decision-making. If we initially refuse your request to exercise rights you believe you have under state law, you may appeal for reconsideration, and the request will be re-considered by our senior management.

Verification of Identity for Exercise of State Law Rights

If you contact us to exercise a right under state law, such as the right to access, verify or correct your PII, before granting access we will take reasonable steps to verify your identity securely. We will not use any additional PII acquired by us in this process other than for the purpose of verifying your identity. Our procedure is to match identifying information provided by you with PII held by us, but we may need to request additional information to verify your identity (to be used solely for the purpose). We may also use a third-party identification service. We will not discriminate or take any adverse action against you for exercising these rights. You may designate an authorized agent to exercise these rights on your behalf. To exercise these rights, please call us toll-free at 866-839-9342, email us at info@GoodLifeHomeLoans.com, or send us a letter at GoodLife Home Loans, Attention: Customer Relations, 2558 Roosevelt Street, Suite 200B, Carlsbad, CA 92008. We will respond within 10 days or the period required by applicable law. We will comply with verifiable requests within 45 days (90 days if we notify you of the reason for the delay), or as required by applicable law.

Requests for Additional Information under State Law. This privacy policy describes the following for the preceding calendar year:

• The categories of PII we collected;
• The categories of sources of PII we collected;
• The purposes for which we collected PII;
• The categories of third parties that received PII from us;
• The categories of business purposes for which we used PII; and
• The categories of PII sold/shared for marketing purposes, and the recipients.

Your state law may give you the additional right to ask us about specific PII we have collected about you during the preceding calendar year.

State Law Rights of Access, Portability, Correction or Deletion. You may have the right to demand access to your PII collected or maintained by us, to require us to provide a copy in data-interchange format, and to require us to correct or delete it.  If we use effective de-identification to satisfy a deletion request, we will maintain the data in de-identified form and not attempt to reassociate it with PII. Applicable laws, regulations and legal obligations may prevent us from completely deleting all of your PII. 

State Law Rights in Sensitive PII.  Although the definition of sensitive PII varies by state, this category generally includes PII relating to religious or philosophical beliefs, medical information, sexual orientation or practices, gender identity, and racial or ethnic origin. You may have the right to ask us not to collect sensitive PII, or to limit our use and disclosure of sensitive PII in a way that reasonably corresponds to the purpose of collection.

State Law Rights against Targeted Advertising & Sales of PII.  You may have the right to tell us not to use your PII for targeted or behavioral advertising, meaning advertising based on your personal preferences. You may have a related right, to tell us not to sell your PII for monetary compensation, but such data sales are not part of our business model.

State Law Rights against Automated Decision Making, Biometrics Usage, and Discrimination.  You may have the right to tell us not to use your PII for automated decision-making that has legally significant effects, such as for employment, credit or housing decisions. You may have the right to tell us not to collect PII from certain biometric information, such as identifying characteristics of your voice or facial features.  State law may prohibit us from discriminating against you, including for exercising your privacy rights.

State Law Rights of Minors & Teens.  As noted above, minors are not eligible for HECM loans, so we do not gather PII of minors. If you are under 18 and we somehow acquire your PII, state law may require us to assume that you would select the most privacy-protective options for your PII, unless you expressly tell us otherwise. If you believe we have acquired the PII of a minor, please call us toll-free at 866-839-9342, email us at info@GoodLifeHomeLoans.com, or send us a letter at GoodLife Home Loans, Attention: Customer Relations, 2558 Roosevelt Street, Suite 200B, Carlsbad, CA 92008.