Privacy Policy

7/26/18

General

This Privacy Policy applies when you access or use www.casalending.com, or any other Casa Lending website, online service or mobile application (collectively, the “Services”), which is owned or administered by Construction Loan Services LLC d/b/a Casa Lending (“Casa Lending”) and is for the benefit of Casa Lending and its affiliates and related parties (“we”, “us” and “our”). We are committed to protecting the information that we collect from you. This Privacy Policy describes how we collect, store, use, and protect information that you provide, directly in connection with your use of the Services or indirectly through third parties, to obtain construction funding products or services available through the Services. This Privacy Policy also describes your choices regarding your information. We may amend this Privacy Policy from time to time by posting a revised, dated version on the Services. By visiting or using the Services, you accept the practices described in this Privacy Policy.

The USA Patriot Act

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who submits a loan application

What this means for you: When you submit an application with us, we will ask for your name, mailing address, and other personally identifiable information that will allow us to verify your identity. We may also ask to see a driver’s license or other identifying documents.

Information Collected

In connection with your use of the Services, we collect, directly or indirectly, three types of information:

1. Information regarding a business (“Business Information”);
2. Information about the business’s owners and guarantors (“User Information”); and
3. General information (i.e., non-personally identifiable information such as website-use information) that is automatically collected as you interact with the Site (“General Information”).

Business and User Information

In connection with providing Services, we may receive Business Information from users, prospective borrowers, and guarantors including, but not limited to:

• Project, business, or entity name(s)
• Mailing address
• Physical Street Address
• Email address
• Telephone number
• Years in Business
• Business type
• Monthly Revenue
• Bank account information
• Payment processing procedures
• Social network data
• Accounting information and vendor service information

We may also receive User Information that consists of personally identifiable information, including, but not limited to: the owner’s or principal’s name, mailing address, email address, telephone number, date of birth, social security number, and estimated FICO score.

We collect User Information and Business Information from you when you (i) register on the Services, (ii) fill out forms or fields on the Services, (iii) complete an application for a product or service available through the Services or (iv) communicate with us by email, mail, text, telephone, facsimile, or other electronic means. In the course of providing the Services, we may collect additional Business Information or User Information from third parties, including, but not limited to, referral partners, identity verification services, mailing list providers, credit bureaus, and publicly available sources and may combine this information with information we already have about you.

General Information

We collect General Information from your computer, mobile device, or other access device when you use the Site (including downloading and using a mobile application or accessing a mobile-optimized site), view content about the Site on a third-party website, or open emails or links in emails from us. This General Information includes, but is not limited to, information about (i) your Internet connection; (ii) the equipment you use to access the Site and usage details; (iii) your operating system, browser version, and IP address; (iv) your mobile device type, your device’s unique identifier, and your mobile network information, and (v) web pages or advertisements that you view and information that you search for on the Site. As is true of most Services, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We may link this automatically collected data to other information we collect about you.

We and our business partners, affiliates, or analytics or service providers use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by such companies on an individual and aggregated basis.

We also use analytics software to allow us to better understand the functionality of our mobile application. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

Use of Information

One of our primary purposes in collecting Business Information, User Information, and General Information from the Services and from third parties is to establish a safe, smooth, efficient, and customized experience that allows website and mobile users to take full advantage of the products and services available through the Services. We use the information collected through the Services to:

• Enable users to obtain products and services through the Services;
• Facilitate activities and transactions that occur in connection with marketing, underwriting, lending, servicing, and collections;
• Send notifications and information regarding the Services and products or services available through the Services;
• Provide customer support;
• Protect against potentially prohibited or illegal activities, including fraud;
• Fulfill legal requirements;
• Customize and enhance user experience;
• Provide targeted marketing and advertising;
• Measure the performance of and improve the Services or mobile application functionality;
• Manage and protect our information technology infrastructure;
• Administer and manage the security of the Services;
• Compile, use, research, analyze, and generate data analytics reports to better understand our customers.

Information Sharing

We take your privacy seriously and will only share information as described in this Privacy Policy. We may share, whether aggregated or not, Business Information and User Information with business partners, service providers, and other third parties under the following circumstances:

• To support our business operations including, but not limited to, customer services, fraud prevention, secure data storage, and other similar services. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other transfer of all or a portion of our business or an operating unit;
• To fulfill the purpose for which you provide such information to us or any other purpose disclosed by us when you provide the information to us;
• To any third party with your consent;
• To protect the confidentiality or security of your records, to protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability, or for resolving disputes or inquiries;
• To comply with federal, state, or local laws, rules, and other applicable legal requirements, to comply with properly authorized civil, criminal, or regulatory investigations, subpoenas, summons, bankruptcy notices by federal, state, or local authorities, or to respond to judicial process or government regulatory authorities that have jurisdiction over us for examination, compliance, or other purposes as authorized by law; and
• To the extent permitted or required under other provisions of laws to law enforcement, the Federal Trade Commission, or self-regulatory organizations for an investigation related to public safety.

Subject to any manual opt-out request sent to privacy@casa-lending.com, we may otherwise share, whether aggregated or not, Business Information and User Information with our business partners, including for jointly offered products and services, under agreements which restrict our business partners’ use of the information and require business partners to follow policies regarding privacy and safeguarding of User Information and Business Information. Business partners may use such information obtained from us to market their or our products or services to you, including jointly offered products or services.

We may also use, sell, license, or distribute General Information (i.e., non-personally identifiable information) or personally identifiable User Information that has been anonymized so that the information does not identify a specific user without restriction, including, but not limited to, for producing data analytics and reports for business partners or others.

We may notify you via email or a prominent notice on the Services of any change in ownership of User Information and Business Information (including as a result of a merger, acquisition, or sale of all or substantially all of its assets), changes to this Privacy Policy, as well as changes to any choices you may have regarding your personally identifiable information.

Your Access

You may review or modify your Business Information and User Information by logging into your Casa Lending account and updating your user profile. This section of the Services is password protected to better safeguard your information. As a customer, you can update your password, physical address, and phone number at any time on the Services, and if you need to change any other information in your profile, you can contact us at info@casalending.com or 206.267.2650.

We will retain your information for as long as your account is active or as long as reasonably useful for commercial purposes. We may be able to close your application but will need to retain certain information as necessary to comply with applicable laws regarding record keeping, reporting, and audits. Upon request, we can inform you of whether we maintain any of your personally identifiable information.

Your Choices

Providing information regarding your browsing and application activity is voluntary. Most computer systems and browsers offer their own privacy settings. You can adjust your privacy settings to disable the cookies used on the Services. If you disable cookies, you can still use the Services, but your ability to use some features of the Services may be limited. Most mobile phones allow you to control privacy settings, including location-based services, by accessing the device’s settings menu. If you have questions about the privacy settings on your mobile device, you should contact your mobile service carrier.

We, our affiliates, or our business partners may contact you to offer you products and services that may be of interest to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails, telephone solicitations, or other forms of contact from us, our affiliates, and our trusted business partners by following the unsubscribe instructions included in these emails or by contacting us at info@caslending.com or 206.267.2650. You may write to us at Casa Lending, 5601 6th Ave South, Suite 350, Seattle, WA 98108, Attn: Data Privacy Opt-Out. We will respond to your request within a reasonable timeframe. If you no longer wish to receive marketing notifications through the Casa Lending mobile application, you can adjust your device’s privacy preferences by visiting the settings page of the application. Opting out of newsletter or marketing emails or notifications will not stop any non-marketing emails or notifications related to the Service’s functionality or the products or services available through the Services.

Third Party Information Collection

We may partner with third parties to display advertisements on the Services and manage advertisements on other websites or mobile applications. Third parties with whom we partner may use cookies or Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based on your interests and browsing activity. Various browsers may offer their own tools to manage cookies and tracking. Do-Not-Track is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to Do-Not-Track signals. If you wish to limit the collection of information by us or third party partners to provide you with advertising based upon your website browsing activities and interests, you may click here to opt out. To opt out of targeted advertising on your mobile device, iOS users can click here and Android users can click here. Please note that opting out of interest-based/targeted advertising does not limit all advertising. You will continue to receive generic advertisements. To opt out of interest-based advertising or manage your preferences, visit this website.

Links to Third Party Websites

The Services may include links to other websites or mobile applications whose privacy practices may differ from ours. We are not responsible for any practices employed on third-party websites or applications, including the information and content contained on the website or application. If you submit information to a third-party website or application, your information is governed by the third party’s privacy policy. We encourage you to carefully read the privacy policy of any website or application you visit, access, or use. We are also not responsible for the accuracy of information contained on third-party websites or applications, nor do we endorse the products or services advertised or referred to on those sites.

Security of Information

We protect User Information and Business Information by using reasonable physical, electronic, and procedural safeguards in compliance with applicable federal and state regulations. We use computer safeguards such as firewalls and data encryption using Transport Layer Security (TLS) technology. We also limit access to User Information and Business Information to employees who need the information to fulfill their job responsibilities. Such employees are provided access to User Information and Business Information only to the extent necessary to complete their job duties.

We store and process information using third-party servers located in secure data centers in the United States. If you have any questions about the security of User Information and Business Information, you can contact us at the address at the bottom of this policy.

Testimonials

We may display testimonials of satisfied customers of Casa Lending Loans on the Services in addition to other endorsements. With your consent, we may post your testimonial along with the business’s and business owner’s or principal’s name and picture. If you wish to update or delete your testimonial, you can contact us at the address at the bottom of this policy.

Children Under 13

The Services and products or services available through this Services are not intended for children under 13 years-old. Casa Lending does not knowingly solicit data online from or market online to children under 13 years-old. If we knowingly receive a child’s personally identifiable information, we will immediately delete it from our system.

Social Media Widgets

The Services may include social media features, such as the Facebook “Like” button and widgets, or interactive mini-programs that run on the Services. These features may collect your IP address, which page you are visiting on our website or application, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Services. Your interactions with these features are governed by the privacy policy of the company providing it.

Data Retention

We will retain your information for as long as the information is needed to provide you Services. If you wish to request that we no longer use your information to provide you Services, you may contact us at the address at the bottom of this policy. We will nonetheless retain your information to the extent that we deem necessary to comply with our legal or contractual obligations, resolve disputes, or for other business purposes.

Data Collected through the Services

Casa Lending handles customer information provided through the Services in accordance with policies and procedures established by this Privacy Policy and Terms of Service. Inquiries regarding customer information should be directed to info@casalending.com or at the address at the bottom of this policy. A request to remove customer information will be responded to within 30 days of receipt of the request.

Changes to Privacy Policy

Casa Lending reserves the right to change this policy from time to time to accommodate changes in technologies, laws, and user needs. In the event we modify this Privacy Policy, we will communicate these changes to you by posting them on this website and/or by notifying you via email prior to the change becoming effective in the event of any substantive or material changes. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

Any questions or concerns regarding this Privacy Policy or the practices of the Site, please contact us by email at info@casalending.com or with a letter by postal mail to:

Casa Lending

Attn: Data Privacy

1019 39th Ave SE, Suite 220

Puyallup, WA 98374

For inquiries, please call 206.267.2650

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