Privacy Policy
The following statement will help you understand how Comergence Compliance Monitoring, LLC (“Comergence”) collects, uses, and safeguards the personally identifying information you give us when you use this website to order products, enroll as a Comergence Registered Third Party Originator, access the Comergence Realm Portal, or otherwise communicate with us through the “Contact Us” feature on the website.
This Privacy Policy applies to any and all information submitted to or available through Comergence’s compliance maintenance program and website in so much as that information is stored by Comergence, as submitted by all User’s of the Site, but specifically, to Mortgage Lenders and Banks (“Lenders”) and individuals and organizations acting as Third Party Originators and Correspondents (“TPO’s”). The Lenders and TPO’s who use this site acknowledge and accept, and agree to abide by this Privacy Policy.
Comergence’s privacy and security policies demonstrate our responsibility to the individuals from and about whom we receive and report information, and to our customers, who rely on us to safeguard the information they report. If you have any questions or concerns about our privacy and security policies, please contact us 714-740-9000.
We define “Personal Identification Information” as information that can help to locate or identify individuals, e.g. name, address, telephone number, social security number, and email address. “Personal Identification Information” also includes credit card information. Protecting the privacy of Personal Identification Information is one of our utmost concerns.
Visitors to www.comergence.com are subject to important limitations. Please review the Legal Notices which govern your visit to this site.
Information We Collect
When you browse this website, you browse anonymously, unless you purchase a product, apply for enrollment as a Comergence Registered Third Party Originator, access the Comergence Realm Portal, email us or submit a comment or question through the “Contact us” feature. We do not collect or store any Personal Identification Information unless you knowingly and willingly provide it, subject to this Privacy Policy.
When you place an online order or register as a Comergence Third Party Originator, we collect only the information necessary to fulfill the transaction requested. Different applications and systems require different levels of information. Any personal consumer credit information will be gathered pursuant to a Credit Authorization and only for the purposes of performing the requisite due diligence services provided by Comergence on behalf of our member Lenders.
Comergence collects and stores the following information on behalf of its member Lenders:
You may request information, make a suggestion, or ask us a question through the “Contact Us” feature on the website. Upon doing so, we may ask you to provide certain identifying information, such as your name, title, company, type of business, telephone and fax numbers, for the purposes of responding to your request.
We may use any personal information you provide for product purchases, TPO or Lender enrollment, or using the “Contact Us” feature to contact you about your purchase, registration, or application; to provide announcements about products and future developments, to conduct surveys of our customers, to respond to your inquiries and suggestions, and to contact you for other reasons related to offering and improving our services. If you are accepted as a Comergence Registered TPO, some of your Personal Identification Information will be shared with those Member-Lenders you designate you want to conduct business with. We may use and share all of this information, subject to applicable law, with other reputable companies that wish to offer products and services in which our customers may be interested.
We may at some point display employment opportunities on this site. If you choose to submit your resume or other information through our website, we use that information only in considering your application for employment. We will share the information only with employees involved in the hiring decisions. Comergence keeps employment application information strictly confidential, and does not sell, rent, share, or otherwise disclose any personally identifiable employment application information you directly provide, except as required by law.
Use of Information
Comergence makes available to member Lenders the information they need to issue and maintain TPO Approvals (which may include non-public Personal Identification Information and confidential information). Comergence makes available to TPOs and other online viewers information as instructed by the Lender.
Comergence may copy, process, store, use, or manipulate the information stored in the Comergence system for the purpose of disseminating aggregated information on a regional or national level. Comergence may disseminate to the general public information stored in Realm and not restricted from disclosure by law or by the terms of all Agreements appurtenant to the use of this site.
Control of Information
Information submitted by a TPO to a designated Lender will be considered to be under that Lender’s control. Information submitted by a TPO to more than one Lender will be considered to be under the control of each Lender to which it is submitted, individually.
Once information is transmitted to a Lender, as designated by the TPO, information will be the Lender’s responsibility and is subject to any Lender-administered Privacy Policies and any public information laws. Comergence is not responsible for any such information.
Comergence will create a unique identifier associated with each Lender and TPO who uses the Comergence system. The unique identifier is confidential and proprietary to Comergence. Comergence may, in its sole discretion, make this unique identifier public.
Disclosure of Information
Comergence may disclose non-public Personal Identification Information and confidential information stored in the Comergence system if Comergence believes that it is required to do so by law; to protect itself or to protect the rights of another user; to reduce risk of credit or other kinds of fraud; or to comply with a court order or other legal, regulatory, self-regulatory, or governmental mandated policy, procedure, or process.
Comergence uses third-party service providers to help manage the Comergence system, its websites, and databases, to collect and analyze information, and to collect fees. These companies are required to maintain such information as confidential. Comergence, however, is not responsible for the unauthorized access, use, or disclosure of any non-public Personal Identification Information or confidential information by a third party.
If our company assets are acquired by another company, that company will assume responsibility for the personal information collected through this website and it will assume the rights and obligations regarding the information collected through this website, as described in this Privacy Policy.
Breach and Notification
In the event that Comergence becomes aware of a security breach which Comergence believes has resulted, or may result, in the unauthorized access, use, or disclosure of non-public Personal Identification Information of Lender and TPOs, Comergence will promptly investigate the matter and notify the applicable Lenders and TPOs of such breach. Such investigation will be without delay, consistent with (1) legitimate needs of law enforcement; (2) measures necessary to determine the scope of the breach; (3) efforts to identify the individuals affected; and (4) steps to restore the reasonable integrity of the Comergence Realm system.
Choice
We offer you choices as to how we will use the Personal Identification Information that you submit through this website. Your choices encompass both our secondary internal uses (such as providing you with information regarding products and services similar to those you have ordered or enrolled in) and our secondary external uses (such as disclosing information to nonaffiliated third parties). You may advise us of your preferences via email. We will follow your instructions only with respect to information on file. If you submit information subsequently, you must advise us with respect to that information.
Please be aware that we may be unable to delete your historical information and the information of former customers from our records.
Access
Upon request, we will give you access to any of your Personal Identification Information we possess that has been submitted through this website. We permit you to review the personal information you submit to us, and to correct any inaccurate information. You may submit this request via email.
Children
Only adults over the age of 18 may use this website. We do not knowingly use this website to solicit data from or market to children under the age of 13.
Cookies
Our Web Server may write a “cookie”, a small computer file, to your hard drive. We may use cookies to enhance your on-line experience, to facilitate your use of our site, and to collect statistics about your visit to the site. If you buy products through our “shopping cart” feature, we may use a cookie to track your order. The cookies used by this site do not contain Personal Identification Information, such as your name, address, telephone number, email address, or credit card information.
Most web browsers allow you to exercise control over cookie files on your computer by erasing them, blocking them, or notifying you when you receive such files. Please refer to your own browser’s instructions for information on those functions. If you do elect to disable the cookies from this site, please note that you may not be able to use the “shopping cart” or other features of this site.
Information Security
The security of customer information is very important to us, and we take a number of steps to safeguard it. After receiving your Personal Identification Information, we maintain commercially reasonable physical, electronic, and procedural safeguards to protect it from unauthorized access, use, disclosure, loss, or destruction. We limit access to those employees who assist us in providing and administering the products or services you order or enroll in. We also require that third parties to whom we disclose Personal Identification Information adhere to this and establish their own information security procedures. When you purchase a product or enroll as a Comergence Lender or TPO and include Personal Identification Information, specifically credit card information, you may elect to transmit your information through a secure Internet connection.
The Comergence website is protected with a variety of security measures such as change control procedures, passwords, and physical access controls. Comergence also employs a variety of other mechanisms to protect a users’ data from being lost, misused, or altered inappropriately. These controls include data confidentiality policies and regular database backups.
Linked Internet Sites
Comergence may establish relationships with reputable business partners by creating a link between our sites. Although we choose our partners and sites carefully, we are not responsible for the content, maintenance, or privacy policies of those sites. Once you click over to a third-party site, we encourage you to check that site’s privacy policy as any further action is not governed by this Policy.
Comergence prohibits the framing of any materials or information available through the Comergence website and unauthorized hypertext links to the Comergence website. Comergence reserves the right to disconnect or otherwise disable any unauthorized frames or hypertext links.
Policy Changes
Comergence reserves the right to modify or update this Privacy Policy at any time by posting modifications or updates on the Comergence website.
