PRIVACY NOTICE FOR CALIFORNIA CONSUMERS

This PRIVACY NOTICE FOR CALIFORNIA CONSUMERS supplements the information contained in the Privacy Statement of RECOVCO MORTGAGEMANAGEMENT, LLC DBA SPROUT MORTGAGE (“Sprout”; sometimes referred to as, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers”or “you”). Sprout adopts this notice to comply with the California ConsumerPrivacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Sprout collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Sprout has collected the following categories of personal information from consumers within the last twelve (12) months:

Category
Examples
Collected
A. Identifiers.
A real name,  alias, postal address, unique personal identifier, online identifier,  Internet Protocol address, email address, account name, Social Security  number, driver's license number, passport number, or other similar identifiers.
Yes
B. Personal  information categories listed in the California Customer Records statute  (Cal. Civ. Code § 1798.80(e)).
A real name,  alias, postal address, unique personal identifier, online identifier,  Internet Protocol address, email address, account name, Social Security  number, driver's license number, passport number, or other similar identifiers.
Yes
C. Protected classification characteristics under California or federal law.
Age (40 years  or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status,  medical condition, physical or mental disability, sex (including gender,  gender identity, gender expression, pregnancy or childbirth and related  medical conditions), sexual orientation, veteran or military status, genetic  information (including familial genetic information).
Yes
D. Commercial information.
A real name,  alias, postal address, unique personal identifier, online identifier,  Internet Protocol address, email address, account name, Social Security  number, driver's license number, passport number, or other similar identifiers.
No
E. Biometric information.
Records of  personal property, products or services purchased, obtained, or considered,  or other purchasing or consuming histories or tendencies.
No
F. Internet or other similar network activity.
Genetic,  physiological, behavioral, and biological characteristics, or activity  patterns used to extract a template or other identifier or identifying  information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans,  keystroke, gait, or other physical patterns, and sleep, health, or exercise  data.
No
E. Biometric information.
Browsing  history, search history, information on a consumer's interaction with a  website, application, or  advertisement.
Yes
G. Geolocation data.
Physical  location or movements.
No
H. Sensory data.
Audio,  electronic, visual, thermal, olfactory, or similar information.
No
I. Professional or employment-related information.
Current or past  job history or performance evaluations.
Yes
E. Biometric information.
Browsing  history, search history, information on a consumer's interaction with a  website, application, or  advertisement.
Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20  U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education  records directly related to a student maintained by an educational institution or party acting on its  behalf, such as grades, transcripts, class lists, student schedules, student  identification codes, student financial information, or student disciplinary  records.
No
K. Inferences drawn from other personal information.
Profile  reflecting a person's preferences, characteristics, psychological trends,  predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
No

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Sprout obtains the categories of personal information listed above from the following categories of sources:

  • Directly or indirectly from our clients or their agents. For example, from documents that our clients or clients’ brokers and/or representatives provide to us related to the services for which they engage us.
  • Directly and indirectly from activity on our website (www.sproutmortgagedirect.com). For example, from submissions through our website portal or website usage details collected automatically.
  • From third parties that interact with us in connection with the services we perform. For example, from title companies in connection with a mortgage loan application.

Use of Personal Information

Sprout may use or disclose the personal information Sprout collects for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to evaluate property valuation for a loan application, we will submit that information to a title company for a title report.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sprout will not collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Sprout may disclose your personal information to a third party for a business purpose. When Sprout discloses personal information for a business purpose, Sprout enters a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, Sprout has disclosed the following categories of personal information for a business purpose:

  • Category A:            Identifiers.
  • Category B:            California Customer Records personal information categories.
  • Category C:            Protected classification characteristics under California or federal law.
  • Category I:             Professional or employment-related information.

Sprout discloses your personal information for a business purpose to the following categories of third parties:

     
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents)with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data PortabilityRights

You have the right to request that Sprout disclose certain information to you about our collection and use of your personal information over the past 12 months. Once Sprout receives and confirms your verifiable consumer request, Sprout will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

Deletion Request Rights

You have the right to request that Sprout delete any of your personal information collected from you and retained, subject to certain exceptions. Once Sprout receives and confirms your verifiable consumer request, Sprout will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Sprout may deny your deletion request if retaining the information is necessary for Sprout or Sprout’s service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Sprout by either:

Only you or a person registered with the CaliforniaSecretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Sprout cannot respond to your request or provide you with personal information if Sprout cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.  Sprout will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

Sprout will respond to a verifiable consumer request within 45 days of its receipt.  If Sprout requires more time (up to 90days), you will be informed of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the contact information associated with that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily use able and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

Sprout will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Sprout will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

Sprout reserves the right to amend this privacy notice at our discretion and at any time.

Questions? Please call us at 877-212-3243 regarding Sprout’s privacy policy.

Who is providing this notice? Recovco Mortgage Management, LLC dba Sprout Mortgage