We may collect your data through various sources—our website, and we use that information to help us provide the best possible experience for you.
“Personal Information” generally means any information that identifies you as an individual, and any other information we associate with it. We collect a few categories of information, from a few different sources.
Information that is passively collected when you use the Sites, such as by our web servers and by third party analytics tools we use:
- Our system logs may record certain information about visitors to our Sites, including the web request, Internet Protocol (“IP”) address, device and mobile ad identifiers, browser information, interaction with the Sites, pages viewed, app usage, and other such information; we may collect similar information from emails you receive from us that can help us track which emails are opened and which links are clicked by recipients.
- We may detect the physical location of your device by, for example, using GPS information collected by mobile apps or location information shared by your web browser. We collect this information for purposes of enhancing or facilitating our services, such as enabling certain functionalities of the Sites that can provide you with information about promotions or relevant product information near you. Should you wish to opt out of the collection of this information, please adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. Please consult your device settings for further information.
HOW WE MAY USE PERSONAL INFORMATION
We may use Personal Information as permitted by law, for the following business purposes:
- to respond to your inquiries and fulfill your requests
- to send administrative information to you, such as about your account or loan or respond to your inquiries and requests for information
- to communicate with you about loans, services, promotions, campaigns, programs, contests, and accounts
- to inform you about our loan products, promotions, events or other promotional purposes
- to re-contact you if we have not heard from you in a while
- to send you advertising/promotional material from any of our affiliates, and on behalf of our promotional and strategic partners
- to improve your experience with our products and services, such as by personalizing your experience with us
We may also use Personal Information as we believe to be necessary or appropriate for certain essential purposes, including:
- to comply with applicable law and legal process
- to respond to requests from public and government authorities, including public and government authorities outside your country of residence
- to detect, prevent, or investigate potential security incidents or fraud
- to facilitate the functionality of our mobile applications and websites
- to provide important product safety information and notice of product recalls
- to enforce our terms and conditions
- to protect our operations or those of our affiliates
- to protect our rights, privacy, safety or property, security and/or that of our affiliates, you or others
- to allow us to pursue available remedies or limit the damages that we may sustain
HOW PERSONAL INFORMATION MAY BE DISCLOSED
To the extent permitted by law, all of your Personal Information may be disclosed to the following categories of third parties:
- in connection with the essential purposes described above (e.g., to comply with legal obligations)
DO NOT TRACK
THIRD PARTY SITES
We are also not responsible for the privacy and data security practices of other organizations, such as Facebook, Instagram, Apple, Google, Microsoft, Twitter or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer. Please read their privacy policies and consider customized settings on your browser or through your mobile phone to limit disclosure of certain information, such as location data.
With recent events and regulatory changes, our customers and business partners are increasingly asking how Town Square Mortgage protects the sensitive information entrusted to us. We recognize that this is a significant trust and one that we don’t take lightly. Information Security is a very complex subject, and the technical details are beyond the scope of this document. However, this document will provide a general overview of the Information Security Controls in place and operating at Town Square Mortgage.
The Town Square Mortgage Information Security Program relies on the National Institute of Standards and Technology (NIST) 800 series of standards as the primary framework for our control design, implementation and operation. Those controls include Physical, Technical, Administrative and Procedural controls. We continually invest in and enhance these controls to meet new threats and vulnerabilities. We work with several leading Information Security firms which assist us in the implementation, operation and review of our security controls. This includes periodic assessments and testing.
A significant part of our strategy is our implementation of application virtualization technology throughout Town Square Mortgage. This technology significantly reduces the potential attack points by centralizing the location of borrower data within our datacenters. We replicate data between servers in our primary and secondary data centers – data is never put on tape or other physical media for transport.
Additionally, all of our associates are provided training on the protection of borrower information and are engaged in an active, continual Information Security Awareness program that keeps Information Security in focus all throughout the year.
Town Square Mortgage’s primary tool for loan processing is the Encompass Loan Origination system by Ellie Mae. Additional services (Credit Reporting, Anti-fraud, etc…) are provided by third party organizations via the Ellie Mae Network. Data movement between Ellie Mae software clients to the central server is encrypted throughout transmission. Borrower information stored on the central server is also encrypted while “at rest”. Similarly, information passed through the Ellie Mae Network is encrypted throughout transit.
Secure exchange of information between borrowers and Town Square Mortgage Loan Officers and associates is facilitated by the Encompass eFolder functionality. Additionally, our email system is configured to automatically establish Transport Layer Security with any correspondent email systems that support this encryption mechanism. Finally, we have an Encrypted Email system for communications with those that don’t have access to a secure email system.
We use standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your Personal Information. Unfortunately, no system or network can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us in accordance with the “Contacting Us” section below (note that physical mail notification will delay the time it takes for us to respond to the problem).
We retain Personal Information in accordance with federal, state, and agency guidelines for the period necessary to fulfill the purposes outlined in the Privacy & Security Policies unless a longer retention period is required or permitted by for legal, auditing, or compliance purposes.
We do not intend for our websites or other online services to knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow minors under the age of 13 to disclose their Personal Information to us through the Sites. The Sites are directed to individuals who are permitted to share their Personal Information without parental consent. If you believe that we might have any information from a child under the age of 13, please contact us as directed below in the “Contacting Us” section. You may mark your inquiry “COPPA Information Request.” Parents can learn more about how to protect children’s privacy online here.
Cookies are small pieces of text. They are provided by most websites and stored by your web browser on the computer, phone, or other device that you are using. Cookies serve many purposes. They can help a website remember your preferences, learn which areas of the website are useful and which areas need improvement, and provide you with targeted advertisements or personalized content. Sometimes, cookies are enabled when pixels are placed on a website. Pixels are also referred to as web beacons, clear gifs, and tags. They enable websites to read and place cookies.
Cookies can be first-party or third-party. A first-party cookie is one that you receive directly from Town Square Mortgage when visiting our Site. A third-party cookie is one that you have received from another party, such as Google or Facebook. We do not control what third parties do on other sites. However, we may work with certain third-party providers such as Google or Facebook to permit their cookies to function through our Site so we can learn more about your web experience on our Site and better personalize our services for you.
A persistent cookie is a cookie that is stored by the web browser on your device until it expires or you delete it. The expiration of a persistent cookie is determined by the creator of the cookie and can be upon a certain date or after a length of session time has passed. This means that, for the cookie’s entire lifespan, its information will be transmitted to the creator’s server every time the user visits the website that it belongs to or another website configured to check for that cookie (such as an advertisement placed on that website). For this reason, persistent cookies are also called “tracking cookies.”
A session cookie is created temporarily on your device for use by a website during your visit. This type of cookie may store information you enter and track your activity within the website. A session cookie is deleted after you leave the website or when the web browser is closed. A good example of a session cookie is the shopping cart on an e-commerce site. The session cookie stores the items that you add to your cart so they are not forgotten while you view products on other pages of the website. Using a session cookie, the items will all be in the cart when you go to the checkout page.
Most web browsers let you choose whether to accept cookies. Most also let you delete cookies already set. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options”, “tools” or “preferences” menu.
There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org. Usually, deletion of cookies will anonymize the information associated with the pixel and a website will not receive any further associated information.
The Site may use Strictly Necessary Cookies, Performance Cookies, Functional Cookies, Targeting Cookies and Social Media Cookies. Any of these may be first-party cookies or third-party cookies, persistent or session.
Strictly Necessary Cookies: These are cookies without which you would not be able to use this Site. For example, Strictly Necessary Cookies adjust the Site data transmitted to match your Internet connection, get you to the secure versions of the Site, and help provide services you specifically request. If you set your browser to block these cookies, some parts of the Site will not work. Strictly Necessary Cookies do not store any Personal Information.
Performance Cookies: We may use these cookies to count visits and traffic sources, to measure and improve Site performance. They help us to know which pages are the most and least popular and see how visitors move around the site. Performance Cookies do not store any Personal Information.
Functional cookies: These cookies allow the Site to remember choices you make and provide enhanced functionality and more personalized features. Depending on context, Functional Cookies may store certain types of Personal Information as needed to provide functionality.
Targeting Cookies: Targeting cookies help us manage and display our advertisements, based on your activity on the Site and other sites; this is known as interest-based advertising. Targeting cookies mainly rely on uniquely identifying your browser and internet device. Opting out of interest-based advertising does not mean you will no longer see advertising online, but it does mean that the companies from which you opt out will no longer show ads that have been tailored to your interests.
Social Media Cookies: Social Media Cookies make social sharing easier for you, provide you with tools to connect with the Site, and help us better understand both the audience for the Site and the effectiveness of our social media outreach. These are third-party cookies. Your choices with respect to such cookies are determined by the social media platforms on which you have accounts.
UPDATES TO THE PRIVACY & SECURITY POLICIES
We may periodically update the Privacy & Security Policies. Any changes will become effective when we post the revised Privacy & Security Policies on our Sites. Your use of the Sites following these changes means that you accept the revised Privacy & Security Policies.
We welcome your questions, comments, and concerns about privacy and security. If you have any questions about the Privacy & Security Policies or our data practices, please contact us:
Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in any emails to us.