Privacy Policy

You are a valued customer and we at Lower, LLC (“Lower” or “Company”) strongly believe in protecting the confidentiality and security of the information we collect about you as a customer, potential customer, or former customer. We have adopted the following policy to safeguard the personal information about you in our possession. Lower requires that its organization, employees, and its DBA/Other Trade Names, comply with all requirements of this policy.  

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. These include among other things, procedures for controlling access to customer files, security programs, and information technology security measures such as the use of passwords and firewalls, as well as virus and use detection software.
• All data is stored on encrypted disks divided by user security groups. Access to this data requires multi-factor authentication through Citrix Workspace. We use Sophos AV and Advanced Threat detection along with Mimecast for email security. 
• We continue to assess new technology as it becomes available and to upgrade our physical and electronic security systems as appropriate.
• 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 of our employees, requires all employees to safeguard personal information about the consumers and customers we serve or have served in the past.

Information We Collect About You

We collect information about you to help us serve your financial needs to provide you with quality products and services and fulfill legal and regulatory requirements. We consider all information about you in our possession to be personal information, even if you cease to be a customer. The personal information we collect about you 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 on applications and other forms you complete, through conversations you may have with our loan professionals, with our other 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 among others, employers, attorneys, banks, lenders, title insurers, insurance companies, credit reporting agencies, our Company’s mobile services, and online web applications. 

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

All financial companies need to share customers’ personal information with third-party companies to run their everyday business. In addition, we may share transactional information with our state and federal regulators. Lower may share your personal information for our day-to-day business purposes, such as to: 

• 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 transaction

• Respond to our Company’s prudential state and federal regulators 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 share personal information about you with its affiliated service providers to assist our company in running day-to-day business activities and operations. Your personal information may also be shared with our affiliates for marketing or joint marketing purposes. The personal information shared by our company may allow our affiliates to market its services and products to you.

Through our Lower app we offer you the option to import your bank account and other information to facilitate the functionality of our app, and we use third party affiliates to accomplish this. By using this app, you accept that we may share your information with these data partners so that you can use the app in all the ways it is intended. With the help of our data partners, we’ll have access to your financial accounts and information as it relates to our app functionality and 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. Our affiliates and third party service providers are required to enter into confidentiality agreements with us, prohibiting them from using any personal information they obtain for any purpose other than those for which they were retained or as required by law. See “To Limit our Sharing” below. 

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 personal information about you to non-affiliated financial service providers to assist our company in running day-to-day business activities and 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. Lower is not permitted, directly or indirectly, to disclose your account number to any non-affiliated third party for marketing purposes.  See “To Limit our Sharing” below. 

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

1. You were provided a privacy notice;
2. You have the opportunity to “opt-out”;
3. You were allotted a reasonable opportunity to opt-out; and 
4. 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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Direct Marketing

We want you to stay informed about our new or existing products! As such, we may directly market our products and services to you through various advertising channels, such as direct mailers and e-mail. To submit requests to limit our direct marketing, please call us at (833) 920-2273.  See “To Limit our Sharing” below for additional information and opt-out details. 

Mobile Numbers

Mobile numbers provided for SMS texting programs will not be shared with non-affiliated financial service providers.  We will not use consumer phone numbers solely for lead generation on behalf of, nor share information with, third parties. 

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Cookies

Our Company may use cookies on its websites and may utilize third party vendors that employ cookies. Any third party vendor is contractually obligated to protect any data they collect on our behalf.  You can always adjust your cookies setting on your computer to prevent such information from being stored without your knowledge or consent. 

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To Limit Our Sharing

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

We can begin sharing your information 30 days from the date we sent this notice unless you authorized us to begin sharing immediately. When you are no longer our customer, we may continue to share your information as described in this notice. You can contact us at any time to limit our sharing. 

If you limit your sharing for an account you jointly hold with someone else, your choices will apply to everyone on the account. 

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

• Sharing for affiliates’ everyday business purposes – information about your creditworthiness.
• Affiliates from using your information to market to you.
• Sharing for non-affiliates to market to you.

You have the right to see what specific pieces of data we have about you, and to get this data in a portable and easily accessible format. You also have the right to request that we delete your data. We’re legally required to keep some data about you, but we’ll delete everything we can in accordance with state and federal law. Keep in mind that we might reacquire some of our data if we purchase data from a third party. To exercise this right please contact us at (833) 920-2273.

State laws and individual companies may give you additional rights to limit sharing.

Changes To Our Privacy Policy

We may make changes to our privacy policy in the future. Whenever we make a meaningful change to the way we handle your personal data, we shall notify you of our company’s updated Privacy Policy to reflect the change(s). You may also contact us directly to receive a physical copy of the updated policy – (833) 920-2273.

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Definitions

• Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. 
• Non-affiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies
• 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. 

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.