Effective Date and Last Revised: February 1, 2024
As used in this Privacy Policy, “Company,” “we,” “our,” and “us” refers to Tri Pointe Connect, LLC, together with its affiliates, subsidiaries, divisions and brands. Please note that where an affiliate of Tri Pointe Connect, LLC has adopted a different privacy policy, such privacy policy will govern as to such affiliate.
The privacy of your personal information is important to us. We have prepared this Privacy Policy and our Cookie Policy to explain how we collect, use, protect, and disclose information and data when you use any Company website displaying this Privacy Policy (“Site”) and other services offered by us (“Services”). This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (defined below). This Privacy Policy applies to all users of the Site and Services.
BY USING THE SITE OR SERVICES, YOU ARE CONSENTING TO THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.
We may update this Privacy Policy from time to time to clarify or inform you of changes to our practices. The Effective Date at the top of this Privacy Notice reflects the last time it was revised. Changes to this Privacy Policy will be effective once they are posted unless otherwise indicated. Please periodically review this Privacy Policy to keep yourself informed regarding how we currently collect, use, protect, and disclose your personal information.
NOTICE FOR CALIFORNIA RESIDENTS
Under the California Consumer Privacy Act of 2018, as amended, if you are a California resident, you may have certain additional rights. If you are a California resident, please see the “California Privacy Section” below.
1. Managing Your Information Preferences
You can review, correct, update, or change your Personal Information, as defined in Section 2, below, or opt out of receiving certain e-mails by e-mailing us at privacy@tripointehomes.com. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as certain informational e-mails. Please note that the Company does not sell to third parties the Personal Information it collects from your use of the Site or from the Services. However, pursuant to applicable law, you may email us at privacy@tripointehomes.com to request that your information not be sold in the future.
If you have other questions or concerns regarding this Privacy Policy, please e-mail us at privacy@tripointehomes.com. We will do our best to respond promptly to you.
2. Information We Collect, Use, and Share
We limit the collection and processing of personal information to that which we need for our business purposes, as explained in the following table and the text that follows it. You may also wish to refer to the disclosures that we are required to make under federal laws applicable to us as a financial institution.
Categories of individuals | Categories of personal information | Purposes | Sources of personal information | Categories of third-party recipients (see below) |
All Users of our Services | · Device, usage, and activity information · Interest and demographic information · Non-precise location information | · Service analysis, security, optimization, and administration | · Directly from individual · Indirectly by observing individuals’ activities or behavior on the Services · Analytics providers | · Analytics providers |
Individuals who use our website to apply or qualify (or pre-quality) for a mortgage loan | · Name and contact information · Employment information · Account access information (username and password) · Social security number, driver’s license number, passport and other government identification numbers · Bank account and credit/debit card numbers · Information about your income, assets, and liabilities · Information for fraud detection and prevention · Payment information for the payment of application and other fees · Home ownership status, location, photos, and approximate value of your property · Other information provided voluntarily by the individual · Demographic and equal opportunity information | · To provide a mortgage loan, qualification for a mortgage loan, or pre-qualification for a mortgage loan · Marketing | · Directly from individual · From third-parties, such as realtors, home builders, lenders, mortgage brokers, employers, attorneys, banks, title insurers, insurance companies, and marketing companies · From credit reporting agencies and other sources of information about your creditworthiness · Payment processors | · Other parties designated by the individual to assist in the processing or settlement of your loan or loan application · With respect to equal opportunity information, with authorized government agencies as required by law |
Individuals identified by our business customers | · Name and contact information | · To enroll in our Services and any personal information contained within training offered to the individual. · Marketing | · From our business customers | · None |
Individuals who voluntarily elect to use the mapping-related features of the Services (the use of mapping-related services is never required) | · Precise location information | · To provide the mapping-related features | · From the individual or the individual’s device or browser | · Google, our provider of map-related services; more information about Google’s use of your personal information is available at https:// policies.google.com/ privacy |
Individuals who apply for employment (the information we process may be limited by law in the jurisdiction where applicants reside) | · Name and contact information · Work history · Education history · Other professional qualifications · References · Compensation data · Information about suitability for employment and for the role sought · Equal employment opportunity information · Information and consent to facilitate pre-employment screening, such as criminal and other background checks · Information about accommodations needed during the application process or for employment · Information about employment eligibility · Emergency contact information | · To consider the individuals for employment, including checking the individuals’ employment eligibility · To administer the employment of individuals selected for hire, including providing for the security of facilities and data/information · For equal opportunity reporting | · Directly from individual · From prior employers, references, and educational institutions identified by the individual (or from data sources that provide such information on behalf of such sources) · From third parties, such as credit reporting agencies and background check firms, that provide information about applicants’ suitability for employment | · Third-party sources indicated in this row who require the applicant’s personal information for identification or authorization purposes |
Individuals who are selected for employment (the information we process may be limited by law in the jurisdiction where applicants reside) | · Work contact information · Information systems credentials (such as usernames and passwords) · Work performance information · Benefits selections and compensation information | · To administer the employment, compensation, and benefits of individuals selected for hire, including providing for the security of facilities and data/information | · Directly from individual · From the employee’s supervisors, peers, and managers | · Taxing jurisdictions (for payroll purpose) · Subsequent employers |
Individuals who send us feedback or other correspondence not covered above | · Sender name and address · Contents of feedback or other correspondence | · To respond to the feedback or other correspondence | · Directly from individual | · None |
Please note that our Services do not process or respond to “do not track” signals or universal opt-out mechanisms.
3. Personal information disclosure and sharing
In addition to the sharing with the third parties described in the table above, we may also share your information with:
4. Personal information security and retention
We use reasonable administrative, technical, and physical safeguards to protect personal information in our possession. While we make every effort to help ensure the integrity and security of our network and systems, you should understand that no data storage system or transmission of data over the internet or any other public network can be guaranteed to be completely secure, accurate, complete, or current.
We retain personal information for as long as is necessary for the purposes for which we use it, or for so long as required by law. What is necessary depends on the context and purpose of processing. We generally consider the following factors when we determine how long to retain personal data:
5. Personal Information of Legal Minors
Our Services are offered, intended, and designed only for use by persons who have attained at least age 18. If you are a parent or guardian of a legal minor who has discovered that your minor child has been using the Services, please inform us using the contact information below.
6. Processing in the United States
Please be aware that your personal information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Services, your personal information and communications will processed in the United States.
7. Text Messages, Website Submissions and Emails
We may communicate information regarding our products and services through email, phone calls, and text messages from time to time. By providing your name and contact information and clicking the submission button in connection with your website submission or inquiry, you consent and agree to receive marketing communications from us or made on our behalf using the communications methods you indicate. These may include emails, calls (which may be made via an artificial or prerecorded voice), and text messages (which may be sent using an automatic telephone dialing system). Your consent and agreement to the foregoing, including the receipt of autodialed marketing messages, is not a condition of purchasing any property, goods, or services from us, and you may call us instead of submitting your information online. By providing your express consent to these communications, you are granting your permission for us to contact you even if you are registered on a national or state Do-No-Call list. For mobile phones, standard text message and data charges apply. If you have consented to receive calls, text messages, or emails from us, you can opt out of receiving future communications at any time by saying or replying “STOP” or “UNSUBSCRIBE” to our call/text message or by clicking the unsubscribe link at the bottom of our email. Message and data rates may apply. Contact your wireless carrier for pricing details if you have any questions regarding your plan’s specific rates.
8. Your Privacy Rights
Depending on the law in the jurisdiction where you live, you may have certain rights regarding your personal information. To exercise your rights, please submit a request by contacting us through any of the means outlined below.
Your rights may include the following:
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. You may also make a request on behalf of your child.
Your request must:
Depending on the jurisdiction in which you reside, your applicable law may grant you the right to appeal the decision we make regarding your data rights request. When you contact us to appeal, please tell us why you believe we erred in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law.
To exercise any of your rights or any questions about our response to you after you request to exercise any of your rights, submit a verifiable Consumer request to us through our privacy portal at https://preferences.tripointehomes.com/privacy or by contacting us at privacy@tripointehomes.com.
A. Nevada Privacy Information
Nevada consumers have the right to opt out of a business’s sale of the consumer’s personal information for monetary consideration. However, we do not sell any personal information of consumers for monetary consideration. Nevada consumers with questions or concerns may contact us through our privacy portal at https://preferences.tripointehomes.com/privacy or by contacting us at privacy@tripointehomes.com.
9. California Privacy Information
We provide the following privacy information for residents of the State of California. Please note that the information provided in this section does not address those personal information processing practices for data that we process subject to the federal Gramm-Leach-Bliley Act or the California Financial Information Privacy Act.
A. Collection of Personal Information
The following table lists the categories of personal information we have collected in the last 12 months in the fashion required by Cal. Civ. Code § 1798.130(a)(5)(B)(i).
Category under the California Consumer Privacy Act | Specific Legal Description | Collected |
A. Identifiers | Identifiers such as 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. Customer records (as defined in Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information or health insurance information. | Yes |
C. Protected classifications | Characteristics of protected classifications under California or federal law, such as 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), and age over 40. | Yes |
D. Commercial Information | Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No |
E. Biometric Information | An individual’s physiological, biological, or behavioral characteristics, including DNA information that is used or is intended to be used to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | No |
F. Usage data | Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. | Yes |
G. Geolocation data | Data intended to locate a customer within a geographic area. | Yes |
H. Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
I. Professional or employment information | Your job role, professional and educational qualifications, employment and education history, compensation information and similar data. | Yes |
J. Education information | Information that is not publicly available personally identifiable information as defined in the California Family Educational Rights and Privacy Act, including 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. | Yes |
K. Inferences | Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes |
B. Collection of Sensitive Personal Information
As required by Cal. Civ. Code § 1798.100(a)(2), the following table lists the categories of sensitive personal information we collect and the purposes for such collection:
Category | Purpose |
Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number. | To consider individuals for employment; for security and quality assurance |
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership. | When provided by an individual in equal opportunity paperwork associated with the individual’s application for employment |
A consumer’s precise geolocation. | To enable individuals to use the map-related features of our Services |
C. Disclosure of Personal Information for a Business Purpose
As required by Cal. Civ. Code § 1798.130(a)(5)(C), the following table lists the categories of personal information that we have “sold” or “shared for cross-context behavioral advertising” with third parties or disclosed for our business purposes in the past twelve months.
Category under the California Consumer Privacy Act | Sold or Shared in the Last 12 Months | Disclosed for a Business Purpose in the Last 12 Months |
A. Identifiers | No | Yes |
B. Customer records (as defined in Cal. Civ. Code § 1798.80(e)) | No | Yes |
C. Protected classifications | No | Yes |
D. Commercial Information | No | Yes |
E. Biometric Information | No | No |
F. Usage data | No | Yes |
G. Geolocation data | No | Yes |
H. Sensory Data | No | No |
I. Professional or employment information | No | Yes |
J. Education information | No | Yes |
K. Inferences | No | No |
To understand more about the purposes for which we collect personal information, see section 1, above.
D. Your Rights
If you are a California resident, California law permits you to request that we disclose certain information about our collection and use of your personal information, excluding personal information governed by the federal Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, including:
E. Appeal process
You may appeal our decision with respect to your request to exercise your legal rights with regard to your personal information. To submit such an appeal, you may contact us using the contact information below. You must include sufficient information to allow us to reasonably verify your identify, reference the date and time of your previous request to exercise your legal rights, and explain why you believe our decision was insufficient or improper. We will respond to your appeal in accordance with the timelines set forth in applicable law.
F. Opting out of the Sale or Sharing of Personal Information
We do not sell or share personal information covered by the California Consumer Privacy Act. With regard to personal information covered under the federal Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, please refer to these disclosures.
G. Exercising Your Other Rights
You may exercise these rights by contacting us per the directions in section 9, below.
Please note that, although you have the right to request that we restrict our processing of sensitive personal information to only that which is necessary to deliver our products and services to you, we already limit our processing of sensitive personal information in this way. If you have any questions or requests relating to this topic, please contact us using the information provided below.
Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your right to the deletion of your information. You may designate an authorized agent to make a request to know or request to delete on your behalf. An agent may be an individual, or a business entity registered with the California Secretary of State. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to verify your identity directly as permitted by law. We may refuse a request if the agent does not provide adequate proof of their authorization.
We may not discriminate against you for exercising any of the above rights as available to you under California law. This means that we may not deny you services, or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to such a request made under California law. However, as permitted by law, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.
H. Shine the Light
California’s “Shine the Light” law, Cal. Civ. Code § 1798.83, entitles California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Any inquiries regarding personal information sharing with third parties may be directed to us at the contact information set forth in section 9, below.
10. How to Submit a Request
To exercise the rights described above, submit a verifiable Consumer request to us through our privacy portal at https://preferences.tripointehomes.com/privacy or by contacting us at privacy@tripointehomes.com.
You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period.
To submit a verifiable Consumer request, you will be asked to provide certain information to help us verify your identity, including your name, email address, phone number and/or information regarding your previous interactions with us. The information we ask you to provide to initiate a request may differ depending upon the type of request; the type, sensitivity and value of the personal information that is the subject of the request; and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.