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E Mortgage Management LLC Privacy Policy for Consumers 2009
Our Privacy Committment To You Privacy Policy Included Information
1 Making The Security Of Information 2 Collection Information 3 Managing Information 4 Honoring Your Preferences 5 Actions You Can Take 6 Guarding Your Own Information 7 Other Privacy Commitments 8 E Mortgage Management LLC Companies Privacy Policy Additional Information
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Trust. Respect. Integrity. Our privacy commitment to you To learn more about how E Mortgage Management LLC manages Customer Information and what actions you can take, please continue reading. We are committed to respecting and protecting our customers’ privacy.
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This document includes information about: 1. Making the security of information a priority 2. Collecting your information 3. Managing information about you 4. Honoring your preferences 5. Actions you can take 6. Guarding your own information 7. Other privacy commitments This policy covers Customer Information, which means personally identifiable information about a consumer or a consumer's current or former customer relationship with E Mortgage Management LLC. The E Mortgage Management LLC Privacy Policy for Consumers is provided to you as required by law and applies to our companies identified in Section 8, E Mortgage Management LLC companies. This policy applies to consumer customer relationships established in the United States and is effective January 1, 2009.
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1. Making the security of information a priority Keeping financial information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards to protect Customer Information. Appropriate employees are authorized to access Customer Information for business purposes only. Our employees are bound by a code of ethics that requires confidential treatment of Customer Information and are subject to disciplinary action if they fail to follow this code.
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2. Collecting your information Customer Information is categorized in the following six ways:
A. Identification Information — information that identifies you such as name, address, telephone number and Social Security number.
B. Application Information — information you provide to us on applications and through other means that will help us determine if you are eligible for products you request. Examples include assets, income and debt.
C. Transaction and Experience Information — information about transactions and account experience, as well as information about our communications with you. Examples include account balances, payment history, account usage and your inquiries and our responses.
D. Consumer Report Information — information from a consumer report. Examples include credit score and credit history.
E. Information from Outside Sources — information from outside sources regarding employment, credit and other relationships that will help us determine if you are eligible for products you request. Examples include employment history, loan balances, credit card balances, property insurance coverage and other verifications.
F. Other General Information — information from outside sources, such as data from public records, that is not assembled or used for the purpose of determining eligibility for a product or service. As required by the USA PATRIOT Act, we also collect information and take actions necessary to verify your identification.
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3. Managing information about you Managing information within E Mortgage Management LLC E Mortgage Management LLC may share any of the categories of Customer Information among our departments. For example, sharing information allows us to use information about your loan application. We occasionally receive from a customer if, for example, a customer applies for mortgage from us. We also may obtain information from organizations not affiliated with E Mortgage Management LLC that prepare and provide reports to others as well as to us. We do not share information among any other companies, except to maintain or collect on accounts, process transactions, service customer requests or perform functions, to the extent permitted by law. Managing information with companies that work for us We may share any of the categories of Customer Information with companies that work for us, including companies located outside the United States. All nonaffiliated companies that act on our behalf and receive Customer Information from us are contractually obligated to keep the information we provide to them confidential, and to use the Customer Information we share only to provide the services we ask them to perform. These companies may include financial service providers such as payment processing companies, and nonfinancial companies such as check printing and data processing companies. In addition, we may share any of the categories of Customer Information with companies that work for us in order to provide marketing support and other services, such as a service provider that distributes marketing materials. These companies may help us to market our own products and services or other products and services that we believe may be of interest to you. Please note that some of our own companies may provide marketing support and other services for us as well.
Sharing information with third parties We may share Identification Information, Transaction and Experience Information, as well as Other General Information we collect.
Disclosing information in other situations We also may disclose any of the categories of Customer Information to credit bureaus and similar organizations and when required or permitted by law. For example, Customer Information may be disclosed in connection with fraud prevention or investigation, risk management and security, and recording mortgages in public records.
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4. Honoring your preferences You have choices when it comes to how E Mortgage Management LLC shares and uses information.
Sharing information with third parties If you have a E Mortgage Management LLC Account, you may request that we not share information about these accounts with third parties. If you request that we not share information with third parties, we may still share information: • Where permitted or required by law as discussed in Section 3 under Managing information within E Mortgage Management LLC; • With our service providers as discussed in Section 3 under Managing information with companies that work for us; and • With other financial companies with whom we have joint marketing agreements. If you have multiple accounts, you will need to express your preference for each account separately. When any customer on a joint account requests that we not share with third parties, we apply that preference to the entire account.
Direct Marketing You may choose not to receive direct marketing offers - sent by postal mail, telephone and/or e-mail - from E Mortgage Management LLC. These preferences apply to all marketing offers from us and from companies working for us. To minimize the amount of telephone solicitation our customers receive, E Mortgage Management LLC does not offer nonfinancial products and services through telephone solicitations. Direct marketing offers from us may include information about products and services we believe may be of interest to you. If you elect not to receive direct marketing offers by postal mail, telephone and/or e-mail, please note that we may continue to contact you as necessary to service your account and for other nonmarketing purposes. You may also be contacted from your client relationship manager or assigned account representative, if applicable. E Mortgage Management LLC may also continue to provide marketing information in your regular account mailings and statements, including online communications. Each customer may opt out of each direct marketing option individually. Since marketing programs may already be in progress, it may take up to 12 weeks for your opt out to be fully effective. When you opt out of direct marketing by postal mail or telephone, your opt out will last for five (5) years. After that, you may choose to renew your opt out for another five-year period.
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5. Actions you can take You can tell us your preferences by: • Notifying us at info@emmloans.com and enter your information. • Calling us toll free at 1.800.793.1400 • Talking to a customer representative or to your client relationship manager You can make sure information is accurate by: • Accessing your account information (for example, on a statement or in response to specific requests) • Telling us if it is incorrect by calling or writing to us at the telephone number or appropriate address for such changes on your statement or other account materials
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6. Guarding your own information E Mortgage Management LLC recommends that you take the following precautions to guard against the disclosure and unauthorized use of your account and personal information: • Review your monthly account statements thoroughly and report any suspicious activity to us immediately. • Do not respond to e-mails requesting account numbers, passwords or PINs. Call the institution to verify the legitimacy of the e-mail. • Memorize PINs and refrain from writing PINs, Social Security numbers, debit or credit card numbers where they could be found. • Shred documents containing any sensitive information before discarding, e.g. bank statements. • Confirm that an Internet site is secure by checking that the URL (Web address) begins with "https”. • Review your credit report at least once every year to make sure all information is up to date. For a free copy of your credit bureau report, contact www.annualcreditreport.com or call 1.877.322.8228. • If you think you have been a victim of identity theft or fraud, you may contact the Federal Trade Commission (FTC) to report any incidents and to receive additional guidance on steps you can take to protect yourself. Contact the FTC at www.ftc.gov/idtheft or 1.877.438.4338. Keeping up to date with our Privacy Policy We may make changes to this policy at any time and will inform you of changes, as required by law. To receive the most up-to-date Privacy Policy, you can visit our Web site at: emmloans.com or call us at 1.800.793.1400.
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7. Other privacy commitments This notice constitutes the E Mortgage Management LLC Do Not Call Policy under the Telephone Consumer Protection Act for all consumers and is pursuant to state law. When you talk with E Mortgage Management LLC by telephone your conversation may be monitored or recorded by us. For information on our Online Practices Privacy Policy please visit www.emmloans.com/onlineprivacypolicy. You may have other privacy protections under state laws, such as Vermont and California. To the extent these state laws apply, we will comply with them with regard to our information practices. For Nevada residents only, We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions in the Section titled “Actions you can take”. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number- 702.486.3132; e-mail: BCPINFO@ag.state.nv.us. For Vermont and California residents only. The information-sharing practices described above are in accordance with federal law. Vermont and California law places additional limits on sharing information about Vermont and California residents so long as they remain residents of those states. • Vermont: In accordance with Vermont law, E Mortgage Management LLC will not share information we collect about Vermont residents with companies outside of E Mortgage Management LLC except as permitted by law, such as with the consent of the customer, to service the customer's accounts or to other financial institutions with which we have joint marketing agreements. E Mortgage Management LLC will not share Application Information, Consumer Report Information and Information from Outside Sources about Vermont residents among the E Mortgage Management LLC companies except with the authorization or consent of the Vermont resident. • California: In accordance with California law, E Mortgage Management LLC will not share information we collect about California residents with companies outside of E Mortgage Management LLC except as permitted by law, such as with the consent of the customer, to service the customer's accounts, or to fulfill on rewards or benefits. We will limit sharing among our companies to the extent required by applicable California law.
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