1. Privacy Pledge / Commitment Statements

  • "We do not sell or rent customer information. Period."
  • "We share customer information with certain employees and with companies providing services on our behalf to service your needs."
  • "We may share your personal information with non-affiliates to assist in your application and mortgage process."
  • "We may share information for marketing and/or joint marketing purposes."
  • "Our policy requires all employees and companies providing services on our behalf to keep customer information safe and to comply with our company's customer information security expectations."
  • "Our privacy policy applies to potential customers as well as current and former customers."
  • "You may have other privacy protections under applicable state laws. To the extent the state laws apply, we will comply with them when we share information about you, and in some cases may be limited by you in what we can share."

2. Safeguarding Personal Information

  • "We have adopted policies and procedures designed to protect your personal information from unauthorized use or disclosure."
  • "We have implemented physical, electronic, and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorized access."
  • "Our policy is to permit employees to access your personal information only if they have a business purpose for using such information, such as administering, providing, or developing our products or services."
  • "Our policy, which governs the conduct of all our employees, requires employees to safeguard personal information about the consumers and customers we serve or have served in the past."

3. Information Collected

  • Employment information.
  • Financial information such as income, assets, liabilities, savings, investments, insurance, and business.
  • Collection from other sources: "employers, attorneys, banks, lenders, title insurers, insurance companies, credit reporting agencies, our Company's mobile services, and online web applications."

4. Sharing Information With Entities

  • Purpose-specific sharing:
    • "Respond to court orders and legal investigations"
    • "Maintain your existing account or application"
    • "Process your transaction"
    • "Report to the credit bureaus"
    • "Service and/or sell your mortgage loan"
    • "Respond to our Company's prudential state and federal regulator's routine requests"
  • Third-party examples: "title companies, appraisers, insurance companies, underwriting services, processing services, loan servicers, printing companies, software providers, data federal and state regulators, marketing services, and purchasers of loans."

5. Sharing With Affiliates

  • "Additionally, we share personal data with our affiliates for marketing or joint marketing efforts."
  • "This allows our affiliates to promote their services and products to you."
  • "When sharing personal information, we may include the following: Your Name, Subject Property Information: Transactional Details (for example Estimated Closing date, Loan Status, and Loan Amount); and Contact Information."
  • "Our affiliates and third-party service providers are bound by confidentiality agreements. These agreements prohibit them from using any personal information for purposes other than those specified or as required by law."
  • "For further details on limiting our sharing, please refer to the section titled 'To Limit Our Sharing.'"

6. Sharing With Non-Affiliates

  • "Lower is prohibited from directly or indirectly disclosing your account number to any non-affiliated third party for marketing purposes."
  • Requirements before disclosure:
    • "You were provided a privacy notice;"
    • "You have the opportunity to 'opt-out';"
    • "You were allotted a reasonable opportunity to opt-out; and"
    • "You elected to not opt-out."

7. Internal and Joint Marketing

  • "We engage in direct marketing through various channels, including direct mailers and email."
  • "We collaborate with other financial institutions and service providers under joint marketing agreements."
  • "If you wish to limit our internal or joint marketing efforts, please call us at (833) 920-2273."

8. Mobile Numbers / SMS

  • "When you provide your mobile number for SMS texting programs, rest assured that we do not share it with non-affiliated financial service providers."
  • "We do not use consumer phone numbers solely for lead generation on behalf of third parties."

9. Cookies

  • "We may employ cookies on our websites and collaborate with third-party vendors who also use cookies."
  • "These vendors are contractually bound to safeguard any data they collect on our behalf."

10. To Limit Our Sharing / Opt-Out Rights

  • Detailed instructions to contact: phone (833) 920-2273 or email optout@lower.com.
  • "We may begin sharing your information 30 days from the date we sent this notice unless you explicitly authorize us to start sharing immediately."
  • Opt-out applies to joint accounts for all holders.
  • "Your request to limit sharing remains effective until you revoke it in writing or agree to revoke it electronically."

11. Your Rights Under Federal Law

  • Limits on:
    • "Sharing for Affiliates' Everyday Business Purposes"
    • "Affiliates' Marketing Use"
    • "Non-Affiliates' Marketing"

12. Your Data Rights

  • Access: "You can request to see the specific pieces of data we hold about you. We will provide this information in a portable and easily accessible format."
  • Deletion: "You have the right to request the deletion of your data. While we are legally required to retain some information, we will delete everything we can in accordance with state and federal laws."
  • Third-Party Data: "Keep in mind that if we purchase data from a third party, we may re-acquire some information."
  • To exercise rights: phone (833) 920-2273.

13. Definitions

  • Affiliates, Non-affiliates, Joint Marketing, Opt-out, Cookies

14. State-Specific Notices

  • California: "We will not share your information with companies outside of our company, except for our everyday business purposes, for marketing our products and services to you, or with your consent."
  • Vermont: "Vermont is an 'opt in' state; not an 'opt out' state… Non-public personal financial information may not be shared with others except as permitted by law unless the Vermont consumer specifically consents…"

15. Credit Reporting / Fair Credit Reporting Act

  • "Important Notice about Credit Reporting" section.
  • "This notice is provided to you in accordance with § 601 et seq. of the Federal Fair Credit Reporting Act (FCRA)."
  • Right to obtain credit report within 60 days of adverse action.
  • Right to dispute accuracy of information.

16. Telephone Communications

  • Monitoring/recording notice.
  • "Do Not Call" list compliance and effectiveness for at least five (5) years.

✅ Summary:

The first privacy policy is missing all of the above sections/content. Essentially, it focuses on general collection, cookies, and security, but does not include:

  • Explicit privacy pledges (e.g., "we do not sell or rent information")
  • Employment/financial info collection
  • Detailed affiliate/non-affiliate sharing and opt-out rights
  • Internal and joint marketing details
  • Mobile/SMS-specific protections
  • Federal/state-specific compliance notices (CA, VT)
  • Credit reporting rights
  • Telephone communication/Do Not Call compliance
  • User data access and deletion rights
  • Definitions of key terms (affiliates, joint marketing, etc.)

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