Last Update: December 10, 2003.
The Privacy Policy below governs your Lender's Office
account and any information you provide on this site.
I. Overview
In order to use Lender's Office and to reduce the risk
of collection, Insight Lending Solutions (ILS) may ask
you to provide information about yourself and your credit
card and/or bank account. This Privacy Policy describes
the information we collect and how we use that information.
ILS takes the privacy of your personal information very
seriously and will use your information only in accordance
with the terms of this Privacy Policy. We will not sell
or rent your personally identifiable information, your
customer list, or a list of our customers to third parties.
However, as described in more detail in Part C below,
there are limited circumstances in which some of your
information will be shared with third parties, under strict
restrictions, so it is important for you to review this
Privacy Policy. This Privacy Policy applies to all services
that are hosted on the LendersOffice.com Web site, whether
the services are offered by ILS or by its subsidiaries.
By accepting the Privacy Policy in using the Lender's
Office system, you expressly consent to our use and disclosure
of your personal information in the manner described in
this Privacy Policy. This Privacy Policy is incorporated
into and subject to the terms of the Service Agreement
of ILS.
Please note that your personal information will be stored
and processed on our computers in the United States. The
laws on holding personal data in the United States may
be less stringent than the laws of your country but ILS
will hold and transmit your personal information in a
safe, confidential and secure environment. If you object
to your personal information being transferred or used
as described in this Privacy Policy, please let us know.
Notification of Changes
This policy may be revised over time as new features are
added to the Lender's Office or as we incorporate suggestions
from our customers. If we are going to use or disclose
your personally identifiable information in a manner materially
different from that stated at the time we collected the
information, you will have a choice as to whether or not
we use or disclose your information in this new manner.
Any material changes will be effective only after we provide
you by e-mail with at least 30 days' notice of the amended
Privacy Policy (if you have closed your ILS account, you
will not be contacted to notify you of the amended Policy
and your personal information will not be used or disclosed
in this new manner).
We will post the amended Privacy Policy prominently on
our Web site so that you can always review what information
we gather, how we might use that information, and whether
we will disclose it to anyone.
Lender's Office may include links to third party Web sites.
These sites are governed by their own privacy statements,
and ILS is not responsible for their operations, including
but not limited to their information practices. Users
submitting information to or through these third party
Web sites should review the privacy statement of these
sites before providing them with personally identifiable
information.
II. Information We Collect
Required Information
To open a Lender's Office account, you must provide your
name, company name, address, phone number, fax number,
and e-mail address. For the purpose of paying your bill,
ILS may require you to provide credit card, debit card
or bank account information.
Transaction
Information
We retain information on consumers that you enter into
Lender's Office for your company use. We also collect
the Internet address (IP address) of the computer or device
you use to access your ILS account, in order to help detect
possible instances of unauthorized transactions.
Information About You From Third Parties
In order to protect all our customers against potential
fraud, we may verify with third parties the information
you provide. In the course of such verification, we receive
personally identifiable information about you from such
services. In particular, if you register a credit card
or debit card with ILS, we will use card authorization
and fraud screening services to verify that your card
information and address matches the information that you
supplied to ILS, and that the card has not been reported
as lost or stolen.
Additional Verification
If we cannot verify the information that you provide,
or if you request your account to be unlocked, we may
ask that you send us additional information by fax (such
as your drivers' license, credit card statement, and/or
a recent utility bill or other information linking you
to the identity of the person owning the account), or
to answer additional questions online to help verify your
information.
Web Site Traffic Information
Because of the way that World Wide Web communication standards
work, when you arrive at or leave Lender's Office, we
automatically receive the Web address of the site that
you came from or are going to. We also collect information
on which pages of our Web site you visit while you are
using Lender's Office, the type of browser you use and
the times you access Lender's Office. We use this information
only to try to understand our customers' preferences better
and to manage the load on our servers, so as to improve
our service and your experience with Lender's Office.
We do not track the Web sites that you visit before or
after you leave the Lender's Office.
Our
Use of "Cookies"
"Cookies" are small files of
data that reside on your computer and allow us to recognize
you as an ILS customer if you return to Lender's Office
using the same computer and browser. We send a "session
cookie" to your computer if and when you log in to your
ILS account by entering your login name and password.
These cookies allow us to recognize you if you visit multiple
pages in our site during the same session, so that you
don't need to re-enter your password multiple times. Once
you log out or close your browser, these session cookies
expire and no longer have any effect.
We also use longer-lasting cookies to store preference
settings, so that you don't have to adjust system settings
each time you log in to your Lender's Office account.
III. Our Use and Disclosure of Information
Internal Uses
We collect, store and process your personal information
on servers located in the United States. We use the information
we collect about you in order 1) to provide our services
and process your transactions, 2) to provide customer
service, 3) to determine your eligibility to receive offers
for special features, and 4) to improve our products and
services. At your option, we use the information you provide
to access specific third party services on your behalf
and perform the actions that you request us to perform
such ordering credit reports.
We give access to individually identifiable information
about our users only to those employees who require it
to fulfill customer service requests.
Disclosure
to Third Parties
ILS will not sell or rent any of your personally identifiable
information to third parties. ILS will not share any of
your personally identifiable information with third parties
except in the limited circumstances described below, or
with your express permission (and to third party services
as described above). These third parties are limited by
law or by contract from using the information for secondary
purposes beyond the purposes for which the information
is shared.
- We share information with companies that help us
process the transactions you request. See "Information
About You From Third Parties" in Section II above.
Additionally, if you go into a negative balance and
owe us money, we may share information with processing
companies including collection agencies.
- We disclose the information we collect, as described
in Section II above, to companies that perform marketing
services on our behalf or to other financial institutions
with whom we have joint marketing agreements. These
companies are subject to confidentiality agreements
with us and other legal restrictions that prohibit
using the information except to market the specified
ILS-related products or services, unless you have
affirmatively agreed or given your prior permission
for other uses.
- We disclose information that we in good faith believe
is appropriate to cooperate in investigations of fraud
or other illegal activity, or to conduct investigations
of violations of our User Agreement. Specifically,
this means that if we conduct a fraud investigation
and conclude that one side has engaged in deceptive
practices, we can give that person or entity's contact
information to victims who request it.
- We disclose information in response to a subpoena,
warrant, court order, levy, attachment, order of a
court-appointed receiver or other comparable legal
process, including subpoenas from private parties
in a civil action. When a user signs up for a co-branded
version of ILS through links on our co-branded partner's
website, ILS will share with the co-branded partner
that user's name, e-mail address and physical address
in order to provide enhanced integration between ILS's
services and the services of our co-branded partner.
If a user does not want his or her information shared
with ILS's co-branded partner, he or she should not
use this aspect of the site.
- We disclose information to your agent or legal representative
(such as the holder of a power of attorney that you
grant, or a guardian appointed for you).
- We share aggregated statistical data with our business
partners or for public relations. For example, we
may disclose that a specific percentage of our users
that are net branches. However, this aggregated information
is not tied to personally identifiable information.
- As with any other business, it is possible that
ILS in the future could merge with or be acquired
by another company. If such an acquisition occurs,
the successor company would have access to the information
maintained by ILS, including customer account information,
but would continue to be bound by this Privacy Policy
unless and until it is amended as described in Section
I above.
- We share your information with our parent, subsidiaries
and joint ventures to help coordinate the services
we provide to you, enforce our terms and conditions,
and promote trust and safety.
Our Contacts with Customers
We communicate with users on a regular basis via e-mail
to provide requested services, and we also communicate
by phone to resolve customer complaints or investigate
suspicious transactions. We use your e-mail address to
confirm your opening of a Lender's Office account, to
send you account statements, to send information about
important changes to our products and services, and to
send notices and other disclosures required by law. Generally,
users cannot opt out of these communications, but they
will be primarily informational in nature rather than
promotional.
In connection with independent audits of our financial
statements and operations, the auditors may seek to contact
a sample of our customers to confirm that our records
are accurate. However, these auditors cannot use personally
identifiable information for any secondary purposes.
Internet Address Information
We use IP addresses, browser types and access times to
analyze trends, administer the site, improve site performance
and gather broad demographic information for aggregate
use.
Your Use of Information and Our Services
By entering into our Agreement, you agree that, with respect
to consumers or other users' personally identifiable information
that you obtain through the site or through an ILS-related
communication or Lender's Office-facilitated transaction,
you will only use this information for: (a) ILS-related
communications that are not unsolicited commercial messages,
(b) using services offered through Lender's Office, and
(c) any other purpose that such consumer or user expressly
agrees to after adequate disclosure of the purpose(s).
In all cases, you must provide consumers or users with
the opportunity to remove themselves from your database
and review any information you have collected about them.
In addition, under no circumstances, except as defined
in this Section, can you disclose personally identifiable
information about another user to any third party without
our consent and the consent of such other user after adequate
disclosure. Note that law enforcement personnel and other
rights holders are given different rights with respect
to information they access.
ILS does not tolerate spam. To report an Lender's Office-related
spam to ILS, please contact us using the method described
in Section V.
IV. Information Security
Information Security
ILS is committed to handling your customer information
with high standards of information security. Your credit
card and bank account information are stored only on computers
that are not connected to the Internet. We restrict access
to your personally identifiable information to employees
who need to know that information in order to provide
products or services to you. We test our security systems
regularly and also contract with outside companies to
audit our security systems and processes. Lender's Office
is hosted at site that is TruSecure certified, which exceeds
the requirements of the Statement on Auditing Standards
(SAS) 70 for service organizations developed by the American
Institute of Certified Public Accountants.
The security of your Lender's Office account also relies
on your protection of your password. You may not share
your Lender's Office password with anyone. ILS will never
ask you to send your password or other sensitive information
to us in an e-mail, though we may ask you to enter this
type of information on the Lender's Office website, which
will always have a URL beginning with http://www.lendersoffice.com/.
Any e-mail or other communication requesting your password,
asking you to provide sensitive account information via
email, or linking to a website with a URL that does not
begin with http://www.lendersoffice.com/ should be treated
as unauthorized and suspicious and should be reported
to ILS immediately. If you do share your Lender's Office
password with a third party for any reason, including
because the third party has promised to provide you additional
services such as account aggregation, the third party
will have access to your account and your personal information,
and you may be responsible for actions taken using your
password. If you believe someone else has obtained access
to your password, please change it immediately by logging
in to your account at www.lendersoffice.com and changing
your Profile settings, and also contact us right away
as described in Section V below.
V. Accessing and Changing Your Information
You can review the personal information you provided us
and make any desired changes to such information, or to
the settings for your Lender's Office account, at any
time by logging in to your account on the Lender's Office
Web site and changing your preferences in the Profile
page of the "My Account" tab. You can also close your
account by contacting us. If you close your Lender's Office
account, we will mark your account in our database as
"Closed," but will keep your account information in our
database. This is necessary in order to deter fraud, by
ensuring that persons who try to commit fraud will not
be able to avoid detection simply by closing their account
and opening a new account. However, if you close your
account, your personally identifiable information will
not be used by us for any further purposes, nor sold or
shared with third parties, except as necessary to prevent
fraud and assist law enforcement, or as required by law.
Contacting Us
If you have any questions about this privacy statement,
ILS’s information practices, or your dealings with Lender's
Office you can contact us by filling out our contact form.
|
