Effective Date: January 1, 2020
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 because our only business is HECM lending, and HECM borrowers are all older than 62 years of age. We do 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, but we promptly honor do-not-contact requests. We take appropriate measures to help protect PII in our control from misuse or unauthorized access.
- 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 the loss, misuse or alteration of information under our control; and
- how you can correct any inaccuracies in the information.
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 a HECM loan from GoodLife®, we will collect and store additional PII including your social security number, income, account balances and payment history, credit history, credit scores and related financial information. 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 your browser can remember your login information 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 1-844-960-2878, 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;
For data analysis, audits, fraud monitoring and prevention, and new product development.
Our Limited Disclosures of Your PII
GoodLife®may disclose your PII as follows:
To Investors: If you apply for a GoodLife®HECM loan, we will share your information with third party investors to whom GoodLife®Home Loans 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 proposal and application processes. You may also contact us to inquire about or correct the accuracy of your records: call us toll-free at 1-844-960-2878, email to info@GoodLifeHomeLoans.com or click here.
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 nature not a perfect or complete defense against malicious actors. Accordingly, we can not 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 1-844-960-2878, email to info@GoodLifeHomeLoans.com or click here.
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 a HECM loan from GoodLife®, we will ask you for limited medical information only as allowed or required by applicable law, and as necessary to consider your application. We will not use or disclose such information except as allowed or required by applicable law, and we will protect such information as required by applicable law.
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 1-844-960-2878, email us at info@GoodLifeHomeLoans.com, or send us a letter at GoodLife® Home Loans, Attention: Customer Relations, 23032 Mill Creek Drive, Suite 62, Laguna Hills, CA 92653.
Special Notice Applicable to California Residents Only:
You have the right to request additional information from us regarding our collection and use of PII, and to ask us to delete your PII collected or maintained by us, if any. To maintain data security, we will verify your identity before taking action on your request. Our procedure for verifying your identity is to match identifying information provided by you with PII held by us. We may need to request additional information to verify your identity, but if so we will use it only to process your request. 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, click here, call us toll-free at 1-844-960-2878, email us at info@GoodLifeHomeLoans.com, or send us a letter at GoodLife®Home Loans, Attention: Customer Relations, 23032 Mill Creek Drive, Suite 62, Laguna Hills, CA 92653. We will respond within 10 days. We will comply with verifiable requests within 45 days (or within 90 days if we notify you of the reason for the delay).
The categories of PII we collected about consumers during the preceding calendar year;
The categories of sources of consumer PII we collected during the preceding calendar year;
The purposes for which we collected consumer PII during the preceding calendar year;
The categories of any third parties that received from us consumer PII that we collected during the preceding calendar year; and whether we sold or shared any consumer PII for marketing purposes (we don’t).
You have the right to ask us to disclose to you and/or delete your specific PII collected or maintained by us, if any. We will not disclose your PII or take action on a request to delete it unless we have first verified your identity. Applicable laws, regulations and legal obligations may prevent us from completely deleting all of your PII, but we will state the reasons for any refusal to delete, and we will retain your request to delete as a record of our compliance.