Privacy Policy

Privacy Policy

Introduction 

Universal Lending Corporation (ULC) recognizes the importance of protecting the confidentiality and security of information that you may choose to provide to us online. This Privacy Policy, in conjunction with our Privacy Notice, (Privacy Notice available below), explains how Universal Lending Corporation (“ULC”, “we,” “us,” or “our”) collect, use and disclose personal information about visitors to our websites, people we meet in person or by phone, our customers and prospective customers (each, “Consumer”, “you,” or “your”), and others whose personal information we collect and retain.

This Privacy Policy applies to:

• Information we receive and collect through ULC.com (“Site”) and any mobile application provided by or on behalf of ULC (collectively, our “Online Services”); and

• Information we receive and collect through email and other electronic means, off-line communications and in-person contacts (collectively with Online Services, “Services”).

Universal Lending Corporation Affiliates is defined in our Privacy Notice under “Affiliates.”

By using any of our Services, you acknowledge the privacy practices we describe in this Privacy Policy. You also acknowledge that you have read this policy and other policies described. Further, you consent to this Policy, including your consent to our use and disclosure of information about you in the manner described below.

1. Personal Information We Collect

What is Personal Information?

The term “personal information” as used in this Privacy Policy refers to information that identifies you as an individual or relates to you as an identifiable individual. We collect your personal information from you through your use of the Services, including the following types of personal information:

Personal Information You Provide

Depending on how you interact with our Services, we will collect the following personal information that you voluntarily provide to us for the following purposes:

• Create an Account. If you create an account, you will provide us with your name, email address, phone number, and you will create a username and password for future logins.

• Get Pre-Qualified. To get pre-qualified, you will provide us with your login credentials, name, email address, date of birth, social security number, citizenship status, marital status, phone number, and physical address.

• Apply for a Mortgage Loan. To apply for a loan with ULC, you will provide us with your login credentials, name, email address, date of birth, social security number, citizenship status, marital status, phone number, and physical address, employment and income information, credit history, purchase property address, and any other additional information we may ask you to provide to assist us with rendering a credit decision. See additional details in Personal Information We Collect.

• Contact Us. If you contact us, you will provide us with your name, email address, phone number, loan or account number, city of residence, state of residence, and any other information you choose to include.

• Find a Branch or Loan Officer. If you search for a branch or Loan Officer in your area, you will provide us with your zip code.

• Careers. If you apply for a job with us, you will provide us with your name, email address, phone number, physical address, employment history, and any other information you choose to provide.

• Share Your Story. If you provide feedback, you will provide us with your name, email address, city of residence, state of residence, and any other information you choose to include.

Personal Information We Collect 

Category of Personal Information	Categories of Recipients
Identifiers (name, postal address, online identifier, Internet Protocol address, email address, Social Security number, date of birth, telephone number, driver’s license, passport)	Affiliates; website hosting providers; payment processors; order fulfillment providers; customer service providers; notaries and auditors; investors; telecommunications providers; marketing providers; government authorities
Nonpublic personal information described in Gramm-Leach-Bliley Act (GLBA) as personally identifiable information (i) provided by a consumer to a financial institution, (ii) resulting from a transaction or any service performed for the consumer, or (iii) otherwise obtained by the financial institution. (for example, bank or asset account numbers, tax returns, income documents, credit reports, underwriting findings, fraud detection reports)	Affiliates; payment processors; order fulfillment providers; customer service providers; notaries and auditors; investors; government authorities
Commercial information (records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies; transaction information)	Affiliates; order fulfillment providers; investors; customer service providers
Demographic information, including characteristics of protected classifications under California or federal law (race, ethnicity, sex/gender, age, citizenship status, marital status)	Affiliates; notaries and auditors; investors; government authorities
Information about your interactions with our websites, mobile app, etc. (IP Address, Device/Advertising ID, mobile provider, operating system, and/or browser, pages visited, browsing history)	Affiliates; data aggregators (Google Analytics; Facebook); marketing systems, investors

 

Personal Information as You Navigate Our Online Services

We automatically collect certain personal information through your use of our Online Services and our use of cookies and other online technologies. This personal information includes:

• Identification Information – Any prior visits to the Online Services, your username and password to access your ULC Account and other personalized services.

• Device Information – Your IP address, browser type, operating system and other usage information about the use of our Online Services.

• Usage Information – Browsing history, search history, and information regarding your interactions with our Online Services and other websites, applications, or advertisements.

• Location Information – Your IP address or mobile device identification transmits general information about your geolocation, and you may allow us to obtain more specific geolocation information.

 

For more information on our cookie usage, see our “Cookies and Other Technologies” section.

 

2. How We Use Your Personal Information

In addition to the purposes stated above, we may use all the personal information we collect in accordance with applicable law such as to:

• Establish, maintain and service our customer accounts, provide customer service, process and or fulfill requests for information, contracts, orders and other transactions, verify customer information, provide financing, title, insurance or other home purchase related services through ULC Affiliates, and to engage in advertising, marketing, and online analytic services;

• Process payment information for transactions with ULC;

• Undertake activities to maintain the quality of ULC products and services and to improve, upgrade, and enhance those products and services, including research and development;

• Manage our Online Services to maintain functionality, assess our users’ feedback so that we present information on your computer or mobile device in a user-friendly way, and to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity and take appropriate action if needed;

• Manage our contractual relations, protect our business interests, enforce our terms and conditions, and comply with applicable laws by monitoring, investigating, and taking other actions to detect and prevent illegal or fraudulent activities and risks to the personal safety of any individual;

• Comply with valid legal process and respond to appropriate governmental requests;

• Facilitate the payment to your creditors if required for your loan transaction, including permitting the escrow service provider to list your full account number on a check or other payment instrument to your creditor;

• Generate an insurance quote by our affiliate insurance company or another insurance company if you opted to receive a quote;

• Fulfill any other purposes for which you provide it; and;

• For any purpose that is reasonably necessary to or compatible with the original purpose for which we collected the personal information as disclosed to you.

3. How We Share Your Personal Information

We may share the personal information that we collect about you in the following ways:

• With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);

• To the extent that we are required to do so by law;

• In connection with any legal proceedings or prospective legal proceedings;

• To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;

• Our Affiliates and any third parties, such as service providers who assist us in the administration, processing, closing, settlement, servicing, and sale of your loan, or other service providers who assist us in fulfilling products and services for you. These third parties include among others, loan origination system providers, lenders, title companies, appraisers, insurance companies, real estate companies, underwriting services, notary services, processing services, printing companies, document providers, software and technology providers, fraud detection companies, and marketing services providers.

• With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information;

• With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;

• With mortgage insurers, government agencies, our investors, warehouse lenders, or other parties who may insure your loan, purchase your loan, or have a security interest in your loan;

• With our federal and state regulatory agencies, investors, or servicers in connection with the sale of your loan or an audit or examination.

• With any other person or entity where you consent to the disclosure; and

• For any other purpose disclosed by us when you provide the personal information or for any other purpose we deem necessary, including to protect the health or safety of others.

4. Cookies and Other Technologies

Like many other companies, we use cookies and similar technologies on our Online Services (collectively, “Cookie”). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile device, or other electronic device (e.g., a tablet).

We use Cookies to:

• Estimate audience size and usage patterns;

• Understand and save your preferences for future visits, allowing us to customize the Online Services to your individual needs;

• Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and

• Recognize when you return to the Site.

Our Sites, websites that may be linked through our Sites, and third-party technology used on our Sites may use cookies for user authentication, promotional campaigns, keeping track of your information and preferences, and tracking other statistical usage information, such as time spent on a particular site or webpage and number of pages visited. We set some Cookies ourselves, while separate entities set other Cookies. We use Cookies other entities set to provide us with useful information, to help us improve our Online Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google.

Browser Settings

 We use both session cookies and persistent cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to our Sites. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser or click on our “Your Privacy Choices” in the footer of our home page to manage your cookie preferences. You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site. 

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

Platform Controls

You can opt out of Cookies set by Google by following the instructions found at My Ad Center (google.com).

Advertising Industry Resources

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies to help us analyze how users interact with the Online Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here. If we use Google Analytics, there will be an opportunity for you to opt out of having such information collected.

Google reCAPTCHA

We use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Site from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. More information as to Google reCAPTCHA and how it works is available here.

5. Opt-Out Preference Signals

Opt-out preference signals (also known as global privacy control or GPC): Some of State Privacy Laws require businesses to process GPC signals, which is referred to in California as opt-out preference signals (“OOPS”), which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the Sale and Sharing of personal information. To use an

OOPS/GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the OOPS/GPC.  We have configured the settings of our consent management platform to receive and process GPC signals on our website, which is explained by our consent management platform here. We process OOPS/GPC with respect to Sales and Sharing that may occur in the context of Collection of cookie PI by tracking technologies online by Third-Party Digital Businesses, discussed above, and apply it to the specific browser on which you enable OOPS/GPC. We currently do not, due to technical limitations, process OOPS/GPC for opt-outs of Sales and Sharing in other contexts (e.g., non-cookie PI).  We do not: (1) charge a fee for use of our service if you have enabled OOPS/GPC; (2) change your experience with any product or service if you use OOPS/GPC; or (3) display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the OOPS/GPC.

6. Security

We maintain commercially reasonable security measures to protect the personal information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

7. Third-Party Links

The Online Services may contain links that will let you leave the Online Services and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

8. Children’s Privacy

The Site and Services are not intended for children under 16 years of age. We do not knowingly collect, use, or disclose personal information from children under 16.

9. California Do Not Track Notice

Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about a consumer’s online activities over time and across third party websites (“Do Not Track” requests), to the extent the operator engages in that collection. At this time, we do not track your personal information over time and across third-party websites and therefore this requirement does not apply to us. ULC does not alter its behavior or change its services upon receiving Do Not Track requests.

California law also requires website and online service operators to disclose whether third parties may collect personal information about their user’s online activities over time and across different sites when the users use the operator’s website or service. Third parties that have content or services on our site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. We do not knowingly permit such third parties to collect any personal information from our site unless you directly provide it to us and we provide it to them with your consent.

10. US State Privacy Laws and Privacy Notice California, Colorado, Texas, or Utah Residents

If you are a California, Colorado, Connecticut, Virginia, or Utah resident, you may be entitled to additional rights over your personal information provided under California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”); Colorado Privacy Act (“CPA”); Texas Data Privacy and Security Act (“TDPSA”); and the Utah Consumer Privacy Act (“UCPA”) All together these statutes are referred to as “State Privacy Laws”. For more information about these rights and how to exercise them, please see our US States Privacy Notice.

Many of the privacy rights described in the US States Privacy Notice do not apply to Personal Information that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and its implementing regulations. Much of the Personal Information that we collect is exempt from the State Privacy Laws. Your choices and rights with respect to our use and sharing of that information are subject to our Privacy Notice below.

This Privacy Policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers, job applicants, employees, or former employees. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on your collective activities. We may also be required to maintain your personal information for at least seven years in order to comply with applicable federal and state laws regarding recordkeeping, reporting and audits. 

11. Notice for California Job Applicants and Employees

If you are a California resident and current or former employee, contractor, or other personnel (collectively, “employee”) as defined in the California Privacy Rights Act, or a job applicant, ULC may collect the following personal information (including sensitive personal information) about you:

• Contact information (such as name, sex, age, date of birth, email address, mailing address, telephone number and identification documents such as residency or work permits, social security number, other taxpayer/government identification number, as well as emergency contact information);

• Professional and employment-related information (such as professional qualifications, prior employment history, education history, references)

• Pre-employment screening (such criminal background check, as permitted by law)

• Organizational data including work contact details (such as address, email, phone number, position/title, job function, employee ID, work eligibility information)

• Contract and compensation data

• Employment-related information (such as benefits information)

• “Sensitive Personal Information” (where permitted and in accordance with applicable law), including biometric data and, of the information listed above, social security number, driver’s license number, age, racial or ethnic origin, health, medical information, and criminal history that may also qualify as personal information.

• Other personal information needed from you to consider your application, and/or conduct employmentrelated business purposes.

• For more information go to US States Privacy Notice

As applicable to job applicant and employment-related personal information, providing the personal information as described in this privacy policy to ULC may be required in order for ULC to fulfill a legal requirement, a contractual requirement under your employment contract, and/or be partially a requirement to carry out the employment relationship with you. In general, you are required to provide such personal information, except in limited instances when we indicate that providing certain information is voluntary (for example, in connection with employee surveys). Not providing personal information where required may prevent ULC from carrying out the employment relationship with you and may require ULC to terminate your employment where permitted by applicable law.

In instances in which providing Sensitive Personal Information is voluntary, we will let you know. If you decide not to share Sensitive Personal Information, that is voluntary, and not doing so will not impact your employment with ULC.

12. Submitting Requests

As outlined in the U.S. States Privacy Notice, under certain State laws, you may submit a request to know, delete, and/or correct through our interactive webform available here.

As outlined in the U.S. States Privacy Notice, privacy rights you may have under State Privacy Laws if you are a customer who has a financial product or service with us, much of the Personal Information that we collect is exempt from State Privacy Laws and, therefore, is not subject to the rights discussed in the U.S. States Privacy Notice. Your choices and rights with respect to our use and sharing of that information are subject to our Privacy Notice.

13. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

14. Changes to Our Privacy Policy

ULC may at any time revise our Privacy Policy, Privacy Notice or Terms of Use. When we do, we will post the revised policy with a new “Last Updated” date.

15. How to Contact Us

If you have any questions about this Privacy Policy, or you want to obtain more information about ULC’s privacy practices, please contact us:

By email: [email protected]

By U.S. Postal Mail: 6430 Fiddlers Green Cir., Suite 460, Greenwood Village, CO 80111

By phone: (800) 768-4063

Privacy Notice

 

FACTS	WHAT DOES UNIVERSAL LENDING CORPORATION (“ULC”) DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect, and share depend on the product or service you have with us. This information can include: § Social Security number and income § Account balances and payment history § Credit history and assets § Employment information
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons ULC chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information		Does ULC share?	Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus		YES	NO
For our marketing purposes – to offer our products and services to you		YES	NO
For joint marketing with other financial companies		NO	NO
For our affiliates’ everyday business purposes – information about your transactions and experiences		YES	NO
For our affiliates’ everyday business purposes – information about your creditworthiness		YES	YES
For our affiliates to market to you		YES	YES
For nonaffiliates to market to you		NO	NO
To limit our sharing	§ Call toll-free (800) 768-4063– our menu will prompt you through your choices or § By Email: [email protected] Please note: If you are a new customer, unless you affirmatively consent to allow ULC to share your information earlier pursuant to law, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Questions?	Call toll-free (800) 768-4063 or by email at [email protected]

 

What we do
How does ULC protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does ULC collect my personal information?	We collect your personal information, for example, when you § open an account or apply for a loan § show your government-issued ID or show your driver’s license § give us your contact information § gives us account information § give us employment and income information We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only § sharing for affiliates’ everyday business purposes—information about your creditworthiness § affiliates from using your information to market to you § sharing for nonaffiliates to market you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account.

 

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include ULC’s parent company, The New Home Company Inc., a residential home builder.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates, sharing is limited to third parties necessary to process your request. We do not share information with other non-affiliated third parties for their marketing purposes.
Joint marketing	ULC does not joint market with non-affiliated third parties who market financial services or products to you.

 

California Consumers: In accordance with California law, we will not share information we collect about you with nonaffiliated third parties, except as permitted by law. For example, we may share information with your consent or as necessary to service or process a financial product or service that you request or authorize. We will also limit the sharing of information about you with our affiliates to the extent required by California law. Please see the U.S. States Privacy Notice at ULC.com for additional information about your privacy choices.