Closing USA (“CUSA”), an affiliate of loanDepot.com, LLC, values your patronage and protecting your personal information is a priority. CUSA believes in protecting the confidentiality and security of the information we collect about you as a customer, potential customer, or former customer. We have adopted the following policies and procedures to safeguard the personal information about you in our possession.
This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal information is protected both electronically and physically.
Our Privacy Pledge
- We do not sell or rent your information.
- We share your information with certain employees and with companies providing services on our behalf in order to service your needs.
- Our policy is to require all employees and companies providing services on our behalf to keep your information confidential.
Safeguarding Personally Identifiable Information
- We have adopted policies and procedures designed to protect your personally identifiable information from unauthorized use or disclosure.
- We have implemented physical, electronic and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorized access. These include among other things, procedures for controlling access to your files, building security programs and information technology security measures such as the use of passwords, firewalls, virus prevention and use detection software.
- We continue to assess new technology as it becomes available and to upgrade our physical and electronic security systems as appropriate.
- Our policy is to permit employees to access your personal information only if they have a business purpose for using such information, such as administering, providing or developing our products or services.
- Our policy, which governs the conduct of all of our employees, requires all employees to safeguard personally identifiable information about the consumers and customers we serve or have served in the past.
CUSA Security Policy
CUSA takes steps to safeguard your personal and sensitive information through industry standard physical, electronic and operational policies and practices. All data that is considered highly confidential data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls and servers with tested operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.
Information We Collect About You
We collect information about you to help us serve your financial needs, to provide you with quality products and services and to fulfill legal and regulatory requirements. We consider non-public information about you in our possession to be personally identifiable information, even if you cease to be a customer. The personally identifiable information we collect about you may include among other things:
- Identifying information, such as your name, age, address, phone number and social security number
- Employment information
- Financial information such as your income, assets and liabilities, as well as information about your savings, investments, insurance and business.
Typically, we collect this information on applications and other forms you complete, through conversations you may have with our agents and representatives, through communications you may have with mortgage loan originators and processors, and in some cases, through our website. We may also collect information from a wide range of other sources in order to participate in the settlement of your loan. These sources may include among others, lenders, employers, attorneys, banks, title insurers, insurance companies, and credit reporting agencies.
We will use your required and optional information to facilitate activities and transactions that need to occur during the lending, title, escrow, and loan settlement process such as:
- Maintaining regular communications with you as may be necessary to settle your mortgage loan, issue title insurance, and perform other title, escrow, and loan settlement processes
- Enabling our affiliates and partners to communicate with you about the loan settlement process, title insurance, and related services and processes
- Carrying out the loan settlement and closing process
- Contacting you if there is a problem completing a transaction you requested
- Informing you about available products and services
- Enabling our financial services partners to implement automatic payments and funds transfer
- Implementing collection activities as needed
- Analyzing and improving our performance
In addition, we gather names and email addresses of people who contact us through our website with questions about our company or operations. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people.
Lastly, we (and/or our service providers) collect information about your computer and your visits to our website, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our website to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies, and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our website based on the needs of our users. Additionally, third parties may collect certain similar information about your computer and other pages you may visit when you visit our website, as discussed further below.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Communications from Us
We may send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.
Links to Third Party Websites
CUSA is not responsible for the information practices employed by sites linked to or from our website. In most cases, links to non-CUSA websites are provided solely as an access point to obtain information on products and topics that may be useful to the users of the CUSA website. Third party websites may have different privacy policies and/or security standards governing their sites.
We may display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at Privacy@closingUSA.com.
Sharing Information with Companies That Provide Services for Us
We share personally identifiable information about you, as required or permitted by law, with third parties, such as service providers who assist us in the in the closing, escrow, title insuring, and settlement of your loan. These third parties include among others, lenders, title companies, appraisers, insurance companies, real estate companies, underwriting services, processing services, printing companies, software providers, marketing services, and purchasers of loans. Our policy is to require third party service providers to enter into confidentiality agreements with us, prohibiting them from using any personally identifiable information they obtain for any other purpose other than those for which they were retained or as required by law. We may also disclose information about you, when necessary or required, in legal and arbitration proceedings and to government agencies.
Web-related Information Collection
If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. On your Apple mobile device, go to Settings, then Safari, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. If you want to disable cookies and you’re using the Chrome browser, go to Settings > Privacy and Security > Cookies and Other Site Data, make the selection that provides the level of tracking you prefer. If you want to disable cookies and you’re using the Explorer browser, go to Settings > Internet Options > Privacy Tab > Advanced, make the selection that provides the level of tracking you prefer. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of the Closing USA website will not be available once cookies are disabled.
California Do Not Track Notice
Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about a consumer’s online activities over time and across third party websites (“Do Not Track” requests), to the extent the operator engages in that collection. At this time, we do not track our customer’s personal information over time and across third-party websites and therefore this requirement does not apply to us. CUSA does not alter its behavior or change its services upon receiving Do Not Track requests.
California law also requires website and online service operators to disclose whether third parties may collect personal information about their user’s online activities over time and across different sites when the users use the operator’s website or service. Third parties that have content or services on our site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. We do not knowingly permit such third parties to collect any personal information from our site unless you directly provide it to us and we provide it to them with your consent.
California Consumer Privacy Act (CCPA)
Compliance with State and Federal Laws
Link to Other Sites
We also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our website you are actually on our site. SSL also ensures that all data entered into the website is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For encryption protection, we use 128-bit secure browser for login and transactions. The application process utilizes “CAPTCHA” technology, which is a test that we use to ensure certain sensitive transactions are being initiated by a human and not by another computer. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering the text shown in the image. We subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.
Making Your Choices
You may have certain choices under applicable federal and state privacy laws to limit our ability to share your personal identifiable information as described in our Privacy Notice. To update your sharing choices please call 1-888-337-6888.
If you choose to receive e-mail messages or newsletters from us, you may later modify your choice by contacting us at 1-888-337-6888. You will also be given the opportunity, in any general bulk commercial e-mail that we send to you, to opt out of receiving such messages in the future. We will attempt to address your request immediately but it may take up to 10 days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as processing requests, conditional loan offers, requests for additional information, service updates or announcements, administrative notices and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of promotional e-mail communications will only affect future activities or communications from us. Note: If we have already provided your information to a third party as part of your loan application then you may have to change your preferences directly with that third party.
Our Do Not Call policy states that you may instruct us not to call you for marketing purposes by informing us at 1-888-337-6888. Our employees are trained through Policies and Procedures to take action on your instructions within 30 days. Please note that we may still need to contact you for legitimate business reasons such as servicing of your loan or other non-marketing purposes.
If you do not want us to send you postal mail for marketing purposes, you may remove your name from current and future mailing lists by contacting us at 1-888-337-6888.
Effective Date of this Policy: 04/04/2022.