California Consumer Privacy Act

This California Consumer Privacy Act Notice ("Notice") is provided by SN Servicing Corporation. The companies are referred to in this Notice as "we" or "us."

This Notice explains how we collect, use, retain, and disclose personal information about California residents. The Notice also explains certain rights that California residents have under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA").

The CCPA applies only to information about residents of California. Under the CCPA, "personal information" is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. This information is referred to in this Notice as "Personal Data."

Please note that SN Servicing adheres to an exemption within the CCPA for data collected pursuant to the Gramm-Leach-Bliley Act (GLBA). This Notice and the rights described do not apply to information we collect when you apply for or obtain our financial products and services for personal, family, or household purposes, which is subject to our Consumer Privacy Notice. This Notice does not apply to SN Servicing subsidiaries and affiliates unless such subsidiary or affiliate links to this policy.

Sharing of Personal Information & Data Retention

In the past 12 months, we have not “sold” Personal Information or Sensitive Personal Information subject to the CCPA. For purposes of this Disclosure, “sold” means the disclosure of Personal Information or Sensitive Personal Information to a third-party for monetary or other valuable consideration.

SN Servicing will keep Personal Data no longer than necessary to fulfil the purposes described in this Notice. Under our record retention policy, we are required to destroy Personal Data after we no longer need it according to specific retention periods. However, we may need to hold Personal Data beyond these retention periods due to regulatory requirements or in response to a regulatory audit, investigation, or other legal matter. These requirements also apply to our third-party service providers.

If you are a California resident or have a California address, we will treat your account as if you opted out from sharing information with affiliated and non-affiliated companies, where prohibited California law.

Categories of Personal Data that We Collect

We collect Personal Data in a variety of contexts. For example, we collect Personal Data to provide financial products and services, for our human resource, and vendor management purposes.

The Personal Data that we collect about a specific California resident will depend on, for example, our relationship or interaction with that individual.

During the past 12 months, we have collected the following categories of Personal Data.

  1. Personal Identifiers — Personal unique identifiers, such as full name and federal or state issued identification numbers including Social Security number, driver’s license number, and passport number
  2. Personal Information — Personal information, including contact details (e.g., telephone number and address), financial information (e.g., account number and balance), payment details (e.g., checking information).
  3. Characteristics of Protected Classes — Characteristics of protected classes or groups under state or federal law, such as sex, disability, citizenship, primary language, immigration status and marital status
  4. Internet or Online Information — Internet or online information regarding interaction with our websites or applications.
  5. Audio and Visual Information — Audio, electronic, visual, or similar information, such as call and video recording
  6. Employment Information — Professional or employment-related information, such as work history and prior employer, information from background checks, resumes, and personnel files
Sensitive Personal Information:
  • Social Security number, driver’s license, state identification card, or passport number;
  • Account log-in, financial account info, password, or credentials allowing access to an account;
  • Racial or ethnic origin
  • Contents of consumer’s mail, email and text messages – N/A unless SN Servicing is the intended recipient
  • Health information

Sources of Personal Data

The sources from which we collect Personal Data depend on, among other things, our relationship or interaction with a specific California resident. The information below lists the categories of sources from which we collect Personal Data in different contexts.
  • From California residents directly, or other individuals acting on their behalf through, for example, physical (e.g., paper application), audible (e.g., phone), and electronic (e.g., website) sources.
  • Public records or widely available sources, including information from the media, and other records and information that are made available by federal, state, and local government entities.
  • Outside companies or organizations from whom we collect Personal Data to support human resource and workforce management activities. Examples may include operating systems and platforms, and social networks.
  • Outside companies or organizations from whom we collect Personal Data as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development. Examples include companies or organizations to whom we provide products or services; other parties, partners, and financial institutions; and parties involved with mergers, acquisitions, and other transactions involving transfers of all or part of a business, or a set of assets.
Why we collect this data
SN Servicing uses types of personal information we collect, depending on the product or service you have with us, to process and maintain your account, as permitted by federal and California state law. This information may be collected for the purposes of:
  • Delivering, managing and supporting products and services, managing relationships and maintaining accounts
  • Performing services on behalf of another business or entity
  • Managing and optimizing internal operations purposes
  • Managing fraud and financial crimes
  • Assessing and managing risk
  • Managing hiring and ongoing employment, such as benefits, and to manage teammate / organizational performance and staffing
  • Meeting legal, regulatory, or compliance requirements
DISCLOSURE OF PERSONAL INFORMATION

During at least the past 12 months, we have shared the following for business or commercial purposes:

  • All categories of Personal Information listed above to our affiliates to the extent permissible under applicable law;
  • Personal Identifiers, Characteristics of Protected Classifications, Demographic Information, Financial Information, Commercial Account and Transaction Information, Audio and Visual Information;
  • All categories of Personal Information listed above may be disclosed to a third party in the event of any proposed reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

During at least the past 12 months, we have shared the following for business or commercial purposes:

  • Personal Identifiers, Characteristics of Protected Classifications, Demographic Information, Financial Information, Account and Transaction Information, Professional, Employment, and Educational Information.
  • We also may use and disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

Where appropriate, we will limit disclosure of your Personal Information in accordance with the choices you have provided us in response to our Privacy Notice(s) or other privacy choices that we may make available.

YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION

You have certain rights with regard to your Personal Information.

A. Your California Privacy Rights

If you are a California resident, you have the right to request and receive certain information about disclosure of your Personal Information to third parties for their direct marketing purposes. Because it is our policy not to share your Personal Information with third parties for third-party direct marketing purposes without your consent, we are exempt from the requirement to respond to such requests. If you have any questions related to our policy, please contact us or submit a request using the information provided in the Contact Us section below. For more information on your rights, you can visit https://oag.ca.gov/privacy/ccpa.

For information regarding how to exercise your rights as a consumer under the California Consumer Privacy Act, please see supplemental provisions for California residents in the Appendix to this Notice.

B. Marketing E-mails

To stop receiving our promotional e-mails, you can follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages.

C. Do Not Track

Some browsers have a Do Not Track feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do respond to browser do not track signals. We do not share any of the info from our web site or from a borrower's activity on our web site with any outside entity. We do not share any tracking formation from our website or from borrower’s activity on our website for any marketing purposes or purposes other than to ensure the safety and security of our systems.

UPDATING YOUR PERSONAL INFORMATION

Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a branch representative, your financial advisor or your designated account representative.

SECURITY OF PERSONAL INFORMATION

The security of your Personal Information is a priority. We seek to protect this information by implementing and maintaining reasonable physical, electronic, and procedural security measures and safeguards designed to protect Personal Information within our organization. We provide employee training in the proper handling of Personal Information. Unfortunately, no data transmission over the Internet or wireless network or data storage system 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 contact us in accordance with the Contact Us section below.

OTHER IMPORTANT INFORMATION

A. Notice of Changes

We may change this Notice from time to time. Any changes will become effective when we post the revised Notice on the Site. Your use of the Sites/Services following these changes means that you accept the revised Notice.

B. Third-Party Sites and Services

This Notice does not address, and we are not responsible for, the privacy, security, or other practices of any third parties, including any third party operating any site or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates.

CONTACT US

If you have any questions about this Notice, please contact your account representative by:

  • Emailing us at CustomerService@snsc.com
  • Dialing TOLL-FREE at (800) 609-0836.

 

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