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, former customer, job applicant, or employee. We have adopted the following policies and procedures to safeguard the personal information about you in our possession.
Based on the products and services you obtain, or employment with CUSA you may have sought or obtained, and/or different laws that may apply to you, additional privacy notices may be provided to you. If you are a resident of California, Colorado, Connecticut, Virginia, Utah or another state for which you may have additional privacy rights, information about these rights may be found US States Privacy Notice section below.
Who We Are
For the purposes of this policy, by “CUSA and its Affiliate companies” or “CUSA” we mean Closing USA LLC and its parent, affiliates, subsidiaries, and joint ventures. This policy does not apply to companies that are not related to CUSA through common ownership (“non-Affiliates"). Data practices of non-Affiliates are governed by their own privacy policies. To see a list of existing CUSA affiliates, subsidiaries, and joint ventures, please see the CUSA and Its Affiliates Companies section below.
Information We Collect About You
Information You Provide Us
We collect information that you provide us and through your use of our site. Information collection occurs when you provide us your information to obtain settlement services or other products or services from us; when you are referred to us through one of our affiliates or joint ventures, or partners; when you communicate with us via third-party platforms, participate in a contest, promotion or survey; when you request customer support or information about our products or services; or when you otherwise communicate with us. In addition, job applicants, current employees, and former employees may provide us information necessary to apply for a job and or to obtain or retain benefits during and after employment as described under the Employees and Job Applicants in this section below and throughout this notice.
The information we collect depends on the context in which you provide it, and may include:
- Identifiers such as full name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, postal address, phone number
- Demographic information such as race, ethnicity, age, and gender that may be required gathered in accordance with federal or state requirements
- Sensitive personal information, which may include social security, driver’s license, state identification card, government identification card, or passport number; account log-in, financial account number in combination with any required security or access code, password, or credentials allowing access to the account
- Home ownership status, location, and approximate value of your property, as well as photos of your property
- Loan, real estate, or financial or credit products or services you have used in the past
- Financial information, such as income, assets, savings, investments, liabilities, and net worth
- Bank account information
- Employment or professional history or status and education information
- Insurance information
- Other profile data, including your interests and preferences
- Information for fraud detection and prevention (including your photo)
- Any other information you may choose to provide
Information We Collect
Consumer and Customers
We collect information about you to help us serve your financial, real estate, and insurance-related, and homeownership-related 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:
- Identifying information, such as your name, age, address, phone number and social security number
- Employment information
- Contact information (such as first and last name, mailing or property address, phone number, email address)
- Account access information, such as username and password
- Demographic information (such as date of birth, gender, marital status, ethnicity, race)
- Social security, driver’s license, passport, and other government identification numbers
- Loan account information (such as loan number)
- Bank account and credit/debit card numbers
- Other personal information needed from you to provide real estate-related, loan-related, insurance-related, and homeownership-related services to you
- Information for fraud detection and prevention
- 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 loan originators and processors; through our service partners; through third parties, such as realtors, home builders, and marketing companies; and in some cases, through our website, online tools, and digital applications. We may also collect information from a wide range of other sources to assist you in your real estate transaction(s), participate in the settlement of your loan, or otherwise provide you with loan, insurance, or homeownership-related products and services. These sources may include among others, lenders, mortgage brokers, employers, attorneys, banks, title insurers, insurance companies, credit reporting agencies, and partners for which, if necessary, we will provide you notice before sharing information and/or that we obtain your consent.
How We Use Your Information
We will use your required and optional information to facilitate activities and transactions that need to occur during the lending, title, escrow, loan settlement, real estate transaction, and other product and service transaction 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 other loan settlement processes; to assist you in a real estate transaction and related real estate settlement processes; or to otherwise complete your real estate or homeownership-related transaction
- Enabling our affiliates and partners to communicate with you about the loan settlement process, real estate transaction, title insurance, and other related services and processes
- Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your transaction, or product or service request
- Informing you about available products and services
- Enabling our financial services partners to implement automatic payments and funds transfer
- Implementing collection activities as needed
We may also use this information to analyze and improve our performance. You may find out more about how we use your personal financial identifiable information here.
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.
Notice for California Job Applicants and Employees
If you are a California resident and current or former employee, contractor, or other personnel (collectively, “employee”) as defined in the California Privacy Rights Act, or a job applicant, CUSA may collect the following personal information (including sensitive personal information) about you:
- Contact information (such as name, sex, age, date of birth, email address, mailing address, telephone number and identification documents such as residency or work permits, social security number, other taxpayer/government identification number, as well as emergency contact information);
- Professional and employment-related information (such as professional qualifications, prior employment history, education history, references)
- Pre-employment screening (such criminal background check, as permitted by law)
- Organizational data including work contact details (such as address, email, phone number, position/title, job function, employee ID, work eligibility information)
- Contract and compensation data
- Employment-related information (such as benefits information)
- “Sensitive Personal Information” (where permitted and in accordance with applicable law), including biometric data and, of the information listed above, social security number, driver’s license number, age, racial or ethnic origin, health, medical information, and criminal history that may also qualify as personal information.
- Other personal information needed from you to consider your application, and/or conduct employment-related business purposes.
- For more information go to US States Privacy Notice
In instances in which providing Sensitive Personal Information is voluntary, we will let you know. If you decide not to share Sensitive Personal Information, that is voluntary, and not doing so will not impact your employment with CUSA.
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.
We retain all information except when required to disclose it to our business partners as a necessary function of the lending, insurance, real estate transaction, or product or service fulfillment process. Such business partners include title and escrow companies, appraisal services, lenders, loan origination system providers, document services, notary services, fraud detection services, as well as our affiliates, joint venture partners, and other third-party service providers (see Sharing Information With Companies That Provide Services For Us section 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.
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.
CUSA does not direct or provide its products or services to children under 16 nor knowingly solicits or collects information from children.
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 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, loan origination system providers, lenders, title companies, appraisers, insurance companies, real estate companies, underwriting services, notary services, processing services, printing companies, document providers, software and technology providers, fraud detection companies, marketing services providers, 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.
Where You Can Find and/or Correct Your Information
If you would like to request correction of your information under your data subject rights as California, Virginia, Colorado, or California resident, you may complete your request by completing this form
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 CUSA website will not be available once cookies are disabled.
To provide you the best digital experience, we use technologies on our websites to monitor and analyze your website activity within the confines of closingusa.com and CUSA associated URLs. Personal data is not collected through the monitoring of website activity. These technologies are embedded on our website and may collect the following information when you interact with the page(s) where the script is present: pages visited, links clicked, modules completed, data entered, keystrokes, and mouse movements. You will be prompted to accept our use of these technologies where in use.
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 your 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.
US State Privacy Laws and Privacy Notice
California Colorado, Connecticut, Virginia, or Utah Residents
If you are a California, Colorado, Connecticut, Virginia, or Utah resident, you may be entitled to additional rights over your personal information provided under California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”); Colorado Privacy Act (“CPA”); Connecticut Data Protection Act (“CTDPA”); Virginia Consumer Data Protection Act (“VCDPA”); and the Utah Consumer Privacy Act (“UCPA”). For more information about these rights and how to exercise them, please see our US States Privacy Notice.
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 or clicking to unsubscribe. 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 or clicking to unsubscribe. 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.
CUSA and Its Affiliates Companies
This policy covers the following companies:
LD Settlement Services, LLC
American Coast Title Company, Inc.
Closing USA of Alabama, LLC
Closing USA LLC
Closing USA of Arkansas, LLC
Commercial Agency USA, LLC
Closing USA of Delaware, LLC
Closing USA of Utah, LLC
A copy of this policy can be printed/downloaded here.
Last update of this Policy: 6/15/2023.