Privacy Policy

As a valued customer, we prioritize the confidentiality and security of the information we collect about you. At Lower, LLC (“Lower” or “Company”), we have implemented a comprehensive policy to safeguard your personal data. This policy applies to all aspects of our organization, including our employees and any other trade names associated with Lower.

Our Privacy Pledge

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.

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.

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Information We Collect About You

At Lower, we gather information to better serve your financial needs, provide quality products and services, and meet legal and regulatory requirements. We treat all information in our possession as personal, even if you are no longer a customer. The data we collect may include, among other things:

Identifying information, such as your name, age, address, phone number, and social security number.
Employment information.
Financial information such as your income, assets, and liabilities, as well as information about your savings, investments, insurance, and business.

Typically, we collect this information through various channels including applications and other forms you complete, conversations with our loan professionals and representatives, and in some cases, over our website. We may also collect information from a wide range of other sources to process and/or underwrite your loan. These sources may include employers, attorneys, banks, lenders, title insurers, insurance companies, credit reporting agencies, our Company’s mobile services, and online web applications.

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Sharing Information with Entities That Provide Services to, or Regulate, our Company

As part of our everyday business operations, financial companies often share customers’ personal information with third-party entities. Additionally, we may disclose transactional details to state and federal regulators. At Lower, we share your personal information for various business purposes, including:

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 parties may include, among others, 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. Lower adheres to all applicable state laws with respect to the sharing of information.

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Sharing Information with Affiliates

Lower may disclose your personal information to affiliated service providers to support our day-to-day business operations. 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.”. ‍

You may want to make a copy of any document for your records when requested to share your information.

Sharing Information with Non-Affiliates

Lower may share your personal information to non-affiliated financial service providers to support our day-to-day business operations. Your personal information may also be shared with such entities for marketing or joint marketing purposes. Your personal information shared may include the following: Your Name, Subject Property Information; Transactional Details (for example Estimated Closing date, Loan Status, and Loan Amount); and Contact Information.

However, Lower is prohibited from directly or indirectly disclosing your account number to any non-affiliated third party for marketing purposes. For further details on limiting our sharing, please refer to the section titled “To Limit Our Sharing.”

Unless otherwise permitted by this policy, Lower may not, directly, or indirectly, disclose your nonpublic personal information to a non-affiliated third party unless:

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.

You may want to make a copy of any document for your records when requested to share your information.

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Lower's Internal Marketing and Joint Marketing Agreements

At Lower, we aim to keep you informed about our new and existing products. To achieve this, we engage in direct marketing through various channels, including direct mailers and email.

Additionally, we collaborate with other financial institutions and service providers under joint marketing agreements. These partnerships allow us to offer you additional services that enhance value. If you wish to limit our internal or joint marketing efforts, please call us at (833) 920-2273. Further details on opting out can be found in the section titled “To Limit Our Sharing.”

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Mobile Numbers

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

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Cookies

At Lower, 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. If you wish to prevent information from being stored without your knowledge or consent, you can adjust your cookie settings on your computer.

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To Limit Our Sharing

To limit the sharing of your information (or opt-out), as allowed by federal and state law, please reach out to us at (833) 920-2273 or email optout@lower.com. Additionally, you can directly opt-out on our website, PrivacyPolicy (lower.com), within the Privacy Policy section.

We may begin sharing your information 30 days from the date we sent this notice unless you explicitly authorize us to start sharing immediately. Even after you are no longer our customer, we may continue to share your information as described in this notice. Feel free to contact us anytime to restrict our sharing.

If you limit sharing for an account that you jointly hold with someone else, your choices will apply to all account holders. Your request to limit sharing remains effective until you revoke it in writing or agree to revoke it electronically.

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Your Rights Under Federal Law

Federal law gives you the right to limit only the following:

Sharing for Affiliates’ Everyday Business Purposes: This pertains to information related to your creditworthiness.
Affiliates’ Marketing Use: You can prevent affiliates from using your information for marketing purposes.
Non-Affiliates’ Marketing: You have the right to limit sharing with non-affiliates for marketing purposes.
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Your Data Rights

As an individual, you have certain rights regarding your personal data:

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 these rights, please contact us at (833) 920-2273. State laws and individual companies may give you additional rights to limit sharing.

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Changes To Our Privacy Policy

Our Privacy Policy undergoes regular reviews to ensure it aligns with data protection practices and complies with legal requirements. If we make any significant changes to how we manage your personal data, we will promptly notify you through our updated Privacy Policy. Additionally, you can always reach out to us directly to receive a physical copy of the revised policy at (833) 920-2273.

Definitions:

Affiliates: Companies related by common ownership or control. They can be financial such as mortgage companies or insurance companies, and nonfinancial companies such as direct marketing companies, technology companies and title companies.

Non-affiliates: Companies not related by common ownership or control. They can be financial such as mortgage companies, insurance companies, credit unions and non-financial companies such as direct marketing companies, technology companies and credit reporting agencies

Joint Marketing: A formal agreement between non-affiliated financial companies that together market financial products or services to you.

Opt-out: A direction by you that the financial institution not disclose certain personal information about you to a non-affiliated third party, except as permitted by law.

Cookies: Text files with small pieces of data that are used to identify and keep track of a website user’s visits and activity.

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Other Information

California Residents: 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 Residents: 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 to the disclosure. In addition, Vermont law prohibits the sharing of credit reports and/or creditworthiness information with affiliates unless the consumer has consented to (“opted-in”) to such sharing.

Important Notice about Credit Reporting: We may report information about your account(s) to credit bureaus and/or consumer reporting agencies. Late payments, missed payments, or other defaults on your accounts(s) may be reflected in your credit report and/or consumer report.

Telephone Communications: All telephone communications with us or our authorized agents may be monitored or recorded for quality control purposes.

Do Not Call: Lower, LLC maintains an internal Do Not Call preference list and complies with the provisions of the Telephone Consumer Protection Act (TCPA) for all consumers. Do Not Call requests will be honored within 30 days and will be effective for at least five(5) years from the date of request. No telemarketing calls will be made to residential or cellular phone numbers that appear on Lower’s Do Not Call List.

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Fair Credit Reporting Act

This notice is provided to you in accordance with § 601 et seq. of the Federal Fair Credit Reporting Act (FCRA). In connection with processing your loan application, we will request a consumer credit report on your credit standing, credit capacity and creditworthiness from a Consumer Reporting Agency. If adverse action is taken on your loan application, we will advise you of the name, address and telephone number of the Consumer Reporting Agency and you will have the right to obtain within 60 days of adverse action a free copy of the consumer credit report from the Consumer Reporting Agency. You also have the right to dispute the accuracy or completeness of any information in the credit report furnished.

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