Privacy Policy

Effective Date: July 13, 2023
Privacy Philosophy

Privacy Philosophy

Homestead Funding Corp. (“HFC”) is dedicated to the protection and transparent use of your personal information.  HFC is a residential loan origination company and we collect certain personal information in connection with that service.   We do not sell or license your data to third-party organizations; however, we do share this information with vendors and other entities during your mortgage loan origination process and after the closing.  This policy will outline how your data is used and your rights and choices associated with the use of HFC’s products and services.

How We Use Your Personal Data

How We Use Your Personal Data

During the loan origination process, we contract with various service providers, including appraisers, title companies, credit organizations, attorneys and others to facilitate certain parts of the transaction.  The information shared with these organizations is limited to the necessary data required to carry out the respective service(s).  HFC has established vendor management policies and requirements for the use and retention of the data that is shared, and selects our vendors based in no small part on their ability to adequately protect and process the data responsibly.

Types of Data Collected

Types of Data Collected

Over the course of your use of HFC’s service, we will collect various types of non-public personal information (“NPI”) as part of our lending process.  This type of information may include but is not limited to:

  • Email Address
  • Name
  • Social Security Number
  • Phone Number
  • Address
  • Passport and/or Driver’s License Information
  • Employment Information
  • Financial Information, which may include income, assets, liabilities and business information.
  • Credit Information
  • Usage Data
  • IP Address
Disclosure of Personal Data

Disclosure of Personal Data

HFC makes every effort to limit the frequency and scope of data shared with third parties.  However, there are instances in which we are required to make such disclosures, either for business or legal purposes.


Legal Disclosures

Occasionally, we will be required by legal or compliance-related circumstances to disclose data to law enforcement, government entities or to the courts under the following circumstances:

  • To comply with a lawful court order or subpoena
  • To protect or defend the rights of HFC
  • To investigate possible misconduct in connection with the use of the service
  • To comply with federal and/or state licensing and/or compliance requirements
  • At the lawful discretion of HFC


Service Providers

HFC contracts with service providers for a number of services completed during the loan process.  These organizations have access to your personal data only for the purpose of performing these tasks on HFC’s behalf.  They are obligated not to disclose this information without authorization or to use the information for any other purpose. The service providers are also required to implement adequate measures to safeguard NPI while it is in their possession.


HFC Does Not Sell Data

All of the personal information and data collected by HFC is used solely for the purposes of carrying out our transactional and compliance responsibilities.  We do not sell, license or otherwise transfer your data to outside companies for profit.

Advertising Practices

Advertising Practices

Behavioral Remarketing

HFC may use third party companies to remarket or optimize advertisements on other website after you have visited our service.  These services may use Cookies or other methods for ad optimization based on your history with our service.


Google

HFC uses the Google platform for internet advertising and analysis.  We would encourage you to visit Google’s Privacy Policies for Google Analytics and Google AdWords for more information about how their services process and track your data.


Facebook

HFC uses the Facebook platform for certain advertising functions.  We do not, however, purchase targeted ads for housing and credit services based on protected class characteristics, geolocation or other criteria that may lead to discriminatory advertising practices.

Data Security

Data Security

HFC prides itself on a robust data security program.  While we are confident that we are using commercially acceptable controls and data privacy resources to maintain the security of your personal information in a manner that complies with relevant state and federal regulation, it is important to remember that no method of data transmission or storage is 100% secure.

Compliance with State and Federal Law

Compliance with State and Federal Law

This privacy policy is intended to provide an overview of your privacy rights while transacting business with HFC.  However, this policy may not constitute the entirety of your legal rights, as privacy laws vary significantly from state-to-state.  Additionally, there may be certain regulations affecting banking transactions in your jurisdiction and you may wish to contact the state agency that oversees privacy protection where you live to be certain of those rights.  

HFC complies with all data protection and compliance requirements in the states in which it is licensed.  HFC is governed by the laws of the United States and it intended for the use of residents of the United States only and makes no representation of compliance with laws of any other nation.

If you are a resident of California, Colorado, Connecticut, Virginia, or any other state with legislation currently in effect that affords its residents additional privacy rights, please see the Additional State Consumer Privacy Rights section below. Further, some states have enacted consumer privacy legislation that will be effective at a future date, which are outlined below. As data privacy legislation is everchanging, the list below will be periodically updated.

Links to Other Websites

HFC website and other online resources may at times link to websites or mobile applications that are not operated by HFC.  If you click on one of these links, you will be directed to that third party’s website or application.  For your privacy protection, we would encourage you to read the privacy policies of non-HFC web locations you may visit, as we have no control over the content, policies or practices of these services.

Changes to Your Personal Data

Changes to Your Personal Data

During your use of HFC’s services, you will interact with your data in several different locations.  In the event you observe incorrect or outdated information, please contact us at privacy@homesteadfunding.com.

Changes to this Privacy Policy

Changes to this Privacy Policy

HFC may make periodic changes to this Privacy Policy.  We will notify you of any material changes by posting the new Privacy Policy to our website and updating the effective date.   Please check periodically for updates and all changes will be effective as of the posted date.

Contact Us

Contact Us

If you have any questions regarding this Privacy Policy, please contact us either via mail directed to: Homestead Funding Corp., Attn: Legal Department, 8 Airline Drive, Albany, New York 12205 or via our toll-free number 1-888-203-5432.

Additional State Consumer Privacy Rights

Additional State Consumer Privacy Rights

The following states have enacted comprehensive data privacy laws for consumers that will be effective as of the dates listed below:

• California Online Privacy Protection Act (effective July 1, 2004)

• California Consumer Privacy Act (effective January 1, 2020), as amended by the California Privacy Rights Act (effective January 1, 2023)

• Colorado Privacy Act (effective July 1, 2023)

• Connecticut Personal Data Privacy and Online Monitoring Act (effective July 1, 2023)

• Indiana Consumer Data Protection Act (effective January 1, 2026)

• Iowa Consumer Data Protection Act (effective January 1, 2025)

• Kentucky Consumer Data Protection Act (effective January 1, 2026)

• Montana Consumer Data Privacy Act (effective October 1, 2024)

• New Hampshire Expectation of Privacy (effective January 1, 2025)

• Rhode Island Data Transparency and Privacy Protection Act (effective January 1, 2026)

• Tennessee Information Protection Act (effective July 1, 2024)

• Utah Consumer Privacy Act (effective December 31, 2023)

• Virginia Consumer Data Protection Act (effective January 1, 2023)

These comprehensive data privacy laws contain provisions such as the right to access and delete personal information (though some exclusions do apply), and the opt-out of the sale of personal information, etc., as described in the sections below.  

Right to Request Disclosure

o You have a right to request that HFC disclose the categories of your data it collects and the specific piece of personal information it has collected.

o You have the right to obtain a portable copy of your personal information maintained by HFC.

Right to Notification

o At or before the time of data collection, you have the right to know the categories or personal information to be collected and the purpose for which the information will be used.  HFC does not collect information beyond that needed to perform the requested services.

Verified Consumer Requests

o Upon receipt of a verified consumer request, you have the right to receive, correct, or delete your personal information.

o In order to complete a verified consumer request, a consumer must, either through our toll-free number or web capture form, submit the request and respond to the representative’s request for verifying information.

Right to Correction

o You have the right to request the correction of inaccurate personal information which HFC maintains.

Right to Deletion

o Upon receipt of a verified consumer request, you have the right to request deletion of the personal information you have provided to HFC.

Right to Third-Party Deletion

o Upon receipt of a verified consumer request, you have the right to request that HFC direct any service providers to delete the consumer’s provided information.

Exemptions to the Right of Deletion

o A business is not required to comply with a consumer’s request for deletion if it is necessary for the business to:

          • Complete the transaction for which the information was provided.

          • Detect security incidents, protect against fraudulent or illegal conduct or prosecute those responsible.

          • Debug to identify or repair errors that impair functionality.

          • Comply with any other state law that may preempt that state’s privacy regulations.

          • To enable solely internal uses that are consistent with the consumer’s relationship to the business.

          • Comply with a legal obligation.

Categories of Disclosure

o You have the right to request the following categories of disclosure from HFC:

          • Categories of information collected.

          • Categories or sources from which the information is collected.

          • Business or commercial purpose of collection.

          • Categories of third parties with whom information is shared.

          • Specific pieces of personal information collected.

Sale of Data/Right to Opt-Out

o You have a right to be informed by HFC if your information may be sold and that you have a right to opt-out of such a sale.  However, HFC does not sell consumer data.

Right to Non-Discrimination

o You have a right to non-discrimination in the event that you exercise any of the rights as listed above.  This includes denial of goods or services, changing prices or rates or providing differing product quality levels.

How We Respond to Do Not Track Requests

o HFC utilizes a number of internet advertising tools, including Google Analytics, AdWords and Facebook advertising functions.   As HFC has no control over the tracking practices of those third parties, we do not currently respond to “Do Not Track” requests.

Single-Transaction Data

o Some states do not require businesses to retain personal information collected for a single, one-time transaction.  HFC does not view our transactions in this manner.

Request Submissions

Request Submissions

When submitting a request exercising any of your rights listed above, it is HFC’s responsibility to ensure that any request is verified to be the same consumer that the requested information identifies.  For consumers who have applied for a loan with us, the requesting party will be required to provide three identifying pieces of information to your HFC representative.

If you have not gone through the formal application process, you will be required to provide two pieces of identifying information to your HFC representative.

As discussed above, requests may be submitted via our toll-free number, 1-888-203-5432 or by filling out the form at the bottom of this page.

Retention of Data

Retention of Data

HFC will retain your personal data for the maximum period required or permitted by law for reasons including but not limited to legal, compliance, or audit purposes.

Categories of Data

Categories of Data

We are required to disclose the categories of data that are collected during your use of the service.  These categories may include:

  • Identifiers
  • Characteristics of Protected Classification
  • Commercial Information
  • Internet or Other Electronic Network Activity
  • Geolocation Data
  • Audio, Visual or Similar Information
  • Profession or Employment Related Information
Disclosure of Data Categories

Disclosure of Data Categories

During the loan process, any of the above categories of data may be disclosed to third parties solely for the transactional services necessary to carry out the responsibilities consistent with the intention of the original collection.  In other words, HFC does not disclose any of the above data categories for any reason than our normal mortgage-related business activities.

GLBA Exemption

GLBA Exemption

The Gramm-Leach-Bliley Act (Public Law 106-102) (“GLBA”) is a federal law that requires financial institutions to explain how they share and safeguard consumers’ sensitive data. This law establishes the basic data privacy rights for all HFC customers, including residents of states that have no state-specific data privacy laws. However, additional privacy rights vary from state to state. This means that the rights listed above are dependent on, among other things, where a customer resides. HFC respects the privacy rights of all customers, including residents of states that have enacted comprehensive privacy laws. Customers will be informed promptly if any request may not be processed due to an applicable state privacy law exemption.