Privacy Policy
The following statement will help you understand how Comergence Compliance Monitoring, LLC (“Comergence”) collects, uses, and safeguards the personally identifying information you give us when you use this website to order products, enroll as a Comergence Registered Third Party Originator, access the Comergence Realm Portal, or otherwise communicate with us through the “Contact Us” feature on the website.
This Privacy Policy applies to any and all information submitted to or available through Comergence’s compliance maintenance program and website in so much as that information is stored by Comergence, as submitted by all User’s of the Site, but specifically, to Mortgage Lenders and Banks (“Lenders”) and individuals and organizations acting as Third Party Originators and Correspondents (“TPO’s”). The Lenders and TPO’s who use this site acknowledge and accept, and agree to abide by this Privacy Policy.
Comergence’s privacy and security policies demonstrate our responsibility to the individuals from and about whom we receive and report information, and to our customers, who rely on us to safeguard the information they report. If you have any questions or concerns about our privacy and security policies, please contact us 714-740-9000.
We define “Personal Identification Information” as information that can help to locate or identify individuals, e.g. name, address, telephone number, social security number, and email address. “Personal Identification Information” also includes credit card information. Protecting the privacy of Personal Identification Information is one of our utmost concerns.
Visitors to www.comergence.com are subject to important limitations. Please review the Legal Notices which govern your visit to this site.
Information We Collect
When you browse this website, you browse anonymously, unless you purchase a product, apply for enrollment as a Comergence Registered Third Party Originator, access the Comergence Realm Portal, email us or submit a comment or question through the “Contact us” feature. We do not collect or store any Personal Identification Information unless you knowingly and willingly provide it, subject to this Privacy Policy.
When you place an online order or register as a Comergence Third Party Originator, we collect only the information necessary to fulfill the transaction requested. Different applications and systems require different levels of information. Any personal consumer credit information will be gathered pursuant to a Credit Authorization and only for the purposes of performing the requisite due diligence services provided by Comergence on behalf of our member Lenders.
Comergence collects and stores the following information on behalf of its member Lenders:
Information provided by the Lender and by TPOs that is used by the Lender to issue and maintain TPO Approvals. This may include non-public Personal Identification Information of TPO’s as well as confidential information submitted by the Lender.
Communications and information relating to such TPO approval, including, without limitation, such matters as TPO Status, Application Approvals, Denials, and amendments made among Lenders and TPO’s through the Comergence system.
Personal Identification Information and Confidential Information to verify the identity of anyone using the Comergence system.
Non-Public Personal Identification Information and other confidential information required to establish a user account. In order to access and use the Comergence system, Lenders and TPO’s must first establish an account (with a unique user name and password). Each Lender and TPO is responsible for all information accessed, used, and/or disclosed through its account.
You may request information, make a suggestion, or ask us a question through the “Contact Us” feature on the website. Upon doing so, we may ask you to provide certain identifying information, such as your name, title, company, type of business, telephone and fax numbers, for the purposes of responding to your request.
We may use any personal information you provide for product purchases, TPO or Lender enrollment, or using the “Contact Us” feature to contact you about your purchase, registration, or application; to provide announcements about products and future developments, to conduct surveys of our customers, to respond to your inquiries and suggestions, and to contact you for other reasons related to offering and improving our services. If you are accepted as a Comergence Registered TPO, some of your Personal Identification Information will be shared with those Member-Lenders you designate you want to conduct business with. We may use and share all of this information, subject to applicable law, with other reputable companies that wish to offer products and services in which our customers may be interested.
We may at some point display employment opportunities on this site. If you choose to submit your resume or other information through our website, we use that information only in considering your application for employment. We will share the information only with employees involved in the hiring decisions. Comergence keeps employment application information strictly confidential, and does not sell, rent, share, or otherwise disclose any personally identifiable employment application information you directly provide, except as required by law.
Use of Information
Comergence makes available to member Lenders the information they need to issue and maintain TPO Approvals (which may include non-public Personal Identification Information and confidential information). Comergence makes available to TPOs and other online viewers information as instructed by the Lender.
Comergence may copy, process, store, use, or manipulate the information stored in the Comergence system for the purpose of disseminating aggregated information on a regional or national level. Comergence may disseminate to the general public information stored in Realm and not restricted from disclosure by law or by the terms of all Agreements appurtenant to the use of this site.
Control of Information
Information submitted by a TPO to a designated Lender will be considered to be under that Lender’s control. Information submitted by a TPO to more than one Lender will be considered to be under the control of each Lender to which it is submitted, individually.
Once information is transmitted to a Lender, as designated by the TPO, information will be the Lender’s responsibility and is subject to any Lender-administered Privacy Policies and any public information laws. Comergence is not responsible for any such information.
Comergence will create a unique identifier associated with each Lender and TPO who uses the Comergence system. The unique identifier is confidential and proprietary to Comergence. Comergence may, in its sole discretion, make this unique identifier public.
Disclosure of Information
Comergence may disclose non-public Personal Identification Information and confidential information stored in the Comergence system if Comergence believes that it is required to do so by law; to protect itself or to protect the rights of another user; to reduce risk of credit or other kinds of fraud; or to comply with a court order or other legal, regulatory, self-regulatory, or governmental mandated policy, procedure, or process.
Comergence uses third-party service providers to help manage the Comergence system, its websites, and databases, to collect and analyze information, and to collect fees. These companies are required to maintain such information as confidential. Comergence, however, is not responsible for the unauthorized access, use, or disclosure of any non-public Personal Identification Information or confidential information by a third party.
If our company assets are acquired by another company, that company will assume responsibility for the personal information collected through this website and it will assume the rights and obligations regarding the information collected through this website, as described in this Privacy Policy.
Breach and Notification
In the event that Comergence becomes aware of a security breach which Comergence believes has resulted, or may result, in the unauthorized access, use, or disclosure of non-public Personal Identification Information of Lender and TPOs, Comergence will promptly investigate the matter and notify the applicable Lenders and TPOs of such breach. Such investigation will be without delay, consistent with (1) legitimate needs of law enforcement; (2) measures necessary to determine the scope of the breach; (3) efforts to identify the individuals affected; and (4) steps to restore the reasonable integrity of the Comergence Realm system.
Choice
We offer you choices as to how we will use the Personal Identification Information that you submit through this website. Your choices encompass both our secondary internal uses (such as providing you with information regarding products and services similar to those you have ordered or enrolled in) and our secondary external uses (such as disclosing information to nonaffiliated third parties). You may advise us of your preferences via email. We will follow your instructions only with respect to information on file. If you submit information subsequently, you must advise us with respect to that information.
Please be aware that we may be unable to delete your historical information and the information of former customers from our records.
Access
Upon request, we will give you access to any of your Personal Identification Information we possess that has been submitted through this website. We permit you to review the personal information you submit to us, and to correct any inaccurate information. You may submit this request via email.
Children
Only adults over the age of 18 may use this website. We do not knowingly use this website to solicit data from or market to children under the age of 13.
Cookies
Our Web Server may write a “cookie”, a small computer file, to your hard drive. We may use cookies to enhance your on-line experience, to facilitate your use of our site, and to collect statistics about your visit to the site. If you buy products through our “shopping cart” feature, we may use a cookie to track your order. The cookies used by this site do not contain Personal Identification Information, such as your name, address, telephone number, email address, or credit card information.
Most web browsers allow you to exercise control over cookie files on your computer by erasing them, blocking them, or notifying you when you receive such files. Please refer to your own browser’s instructions for information on those functions. If you do elect to disable the cookies from this site, please note that you may not be able to use the “shopping cart” or other features of this site.
Information Security
The security of customer information is very important to us, and we take a number of steps to safeguard it. After receiving your Personal Identification Information, we maintain commercially reasonable physical, electronic, and procedural safeguards to protect it from unauthorized access, use, disclosure, loss, or destruction. We limit access to those employees who assist us in providing and administering the products or services you order or enroll in. We also require that third parties to whom we disclose Personal Identification Information adhere to this and establish their own information security procedures. When you purchase a product or enroll as a Comergence Lender or TPO and include Personal Identification Information, specifically credit card information, you may elect to transmit your information through a secure Internet connection.
The Comergence website is protected with a variety of security measures such as change control procedures, passwords, and physical access controls. Comergence also employs a variety of other mechanisms to protect a users’ data from being lost, misused, or altered inappropriately. These controls include data confidentiality policies and regular database backups.
Linked Internet Sites
Comergence may establish relationships with reputable business partners by creating a link between our sites. Although we choose our partners and sites carefully, we are not responsible for the content, maintenance, or privacy policies of those sites. Once you click over to a third-party site, we encourage you to check that site’s privacy policy as any further action is not governed by this Policy.
Comergence prohibits the framing of any materials or information available through the Comergence website and unauthorized hypertext links to the Comergence website. Comergence reserves the right to disconnect or otherwise disable any unauthorized frames or hypertext links.
Policy Changes
Comergence reserves the right to modify or update this Privacy Policy at any time by posting modifications or updates on the Comergence website.
Comergence Website Legal NoticesPlease read these Terms and Conditions carefully before using this Site.The following terms and conditions govern all access to and use of this Site. Through User’s access of this Site, User accepts, without limitation or alteration, all of the terms and conditions contained in these Legal Notices. The trademarks, logos, and service marks (collectively the “Marks” or “Mark”) appearing on the Site are registered and unregistered Marks of Comergence Compliance Monitoring, LLC (“Comergence”) and others. The Site and the information contained therein in no way grant any license or right to use any Mark displayed on the Site. User is strictly prohibited from using the Marks displayed on the Site or any other content on the Site, except as provided in these Legal Notices. Comergence aggressively enforces its intellectual property rights, including criminal prosecution where appropriate. Comergence has established and continues to maintain this Site to provide information, education, and communication. Downloading of material displayed on the Site is limited to non-commercial, personal use only, unless subject to a specific agreement between Comergence and User. The content of this Site cannot be used, posted, sold, transmitted, distributed, modified or transferred for public or commercial purposes, without written permission of Comergence. With the exception of Consumer Personal Identification Information as discussed in this website’s Privacy Policy, any communication or material sent to Comergence or to the Site by email or otherwise, including any data, questions, comments, suggestions, feedback or the like, is, and will be deemed, non-confidential and non-proprietary. Any communication or material sent to Comergence becomes the property of Comergence and may be used for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast, and posting. Furthermore, Comergence is free to use any ideas, concepts, know-how, or techniques contained in any communication sent to the Site for any purpose whatsoever, including, but not limited to, developing and marketing products using such information. Comergence makes no representations whatsoever about any other web site which may be accessed through this Site via a link. Access to a non-Comergence operated website is independent from Comergence, and Comergence has no control over the content of that website. In addition, a link to a non-Comergence website does not mean that Comergence endorses or accepts any responsibility for the content, or the use, of such website. Comergence also assumes no responsibility, and shall not be liable for, any damages to, or viruses that may infect the computer equipment or other property of User arising from or related to access to, or use of, or browsing in the Site or the downloading of any materials, data, text, images, video, or audio from the Site User. In no event will Comergence, its affiliates, its agents, or any other party involved in creating, producing, or delivering the site, be liable to any party for any direct, indirect, exemplary, punitive, special, or other consequential damages for any use of this website, or any other linked site, including, without limitation, any lost profits, business interruption, loss of programs or other data on Users Information Handling System or otherwise, even if Comergence is expressly advised of the possibility of such damages. The Site’s content is copyrighted. Use of the Site’s content is prohibited except as provided herein, without the written permission of Comergence. Although Comergence makes attempts to include accurate and up-to-date information in the Site, Comergence makes no warranties or representations as to its accuracy or timeliness. Comergence assumes no liability or responsibility for any errors or omissions in the content of the site. Information on this Site may contain technical inaccuracies or typographical errors. Comergence may change or update information without notice. Comergence may make improvements and/or changes in the products and/or programs described in this Site at any time without notice. Use of and browsing in the Site are at User’s risk. Without limiting the foregoing or any outstanding agreements, everything on this Site is provided “As-Is” without warranty of any kind, either express or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose, or non-infringement. Some jurisdictions may not allow the exclusion of implied warranties; therefore some of the above exclusions may not apply. Comergence either owns or has permission to use the images displayed on the Site. All of these images are either the property of, or used with permission by Comergence. All uses of these images are prohibited. Use of the images without authorization may violate certain laws, including, but not limited to those relating to copyright, trademark, privacy, and publicity. These Legal Notices are subject to revision at any time by an update to this posting. Such revisions are binding upon any User of this Site. As a result, all Users should routinely visit this page to review the then current Legal Notices to which they are bound. Comergence controls and operates this Site from its offices within the United States of America. Comergence makes no representation that materials in the Site are appropriate or available for use in other locations, and access to them from territories where there contents are illegal is prohibited. Those who choose to access this site from other locations do so on their own initiative and are responsible for compliance with applicable local laws. Any claim relating to the materials will be governed by the substantive laws of the State of California.
Comergence Website Legal Notices
Please read these Terms and Conditions carefully before using this Site.
The following terms and conditions govern all access to and use of this Site. Through User’s access of this Site, User accepts, without limitation or alteration, all of the terms and conditions contained in these Legal Notices.
The trademarks, logos, and service marks (collectively the “Marks” or “Mark”) appearing on the Site are registered and unregistered Marks of Comergence Compliance Monitoring, LLC (“Comergence”) and others. The Site and the information contained therein in no way grant any license or right to use any Mark displayed on the Site. User is strictly prohibited from using the Marks displayed on the Site or any other content on the Site, except as provided in these Legal Notices. Comergence aggressively enforces its intellectual property rights, including criminal prosecution where appropriate.
Comergence has established and continues to maintain this Site to provide information, education, and communication. Downloading of material displayed on the Site is limited to non-commercial, personal use only, unless subject to a specific agreement between Comergence and User. The content of this Site cannot be used, posted, sold, transmitted, distributed, modified or transferred for public or commercial purposes, without written permission of Comergence.
With the exception of Consumer Personal Identification Information as discussed in this website’s Privacy Policy, any communication or material sent to Comergence or to the Site by email or otherwise, including any data, questions, comments, suggestions, feedback or the like, is, and will be deemed, non-confidential and non-proprietary. Any communication or material sent to Comergence becomes the property of Comergence and may be used for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast, and posting. Furthermore, Comergence is free to use any ideas, concepts, know-how, or techniques contained in any communication sent to the Site for any purpose whatsoever, including, but not limited to, developing and marketing products using such information.
Comergence makes no representations whatsoever about any other web site which may be accessed through this Site via a link. Access to a non-Comergence operated website is independent from Comergence, and Comergence has no control over the content of that website. In addition, a link to a non-Comergence website does not mean that Comergence endorses or accepts any responsibility for the content, or the use, of such website. Comergence also assumes no responsibility, and shall not be liable for, any damages to, or viruses that may infect the computer equipment or other property of User arising from or related to access to, or use of, or browsing in the Site or the downloading of any materials, data, text, images, video, or audio from the Site User. In no event will Comergence, its affiliates, its agents, or any other party involved in creating, producing, or delivering the site, be liable to any party for any direct, indirect, exemplary, punitive, special, or other consequential damages for any use of this website, or any other linked site, including, without limitation, any lost profits, business interruption, loss of programs or other data on Users Information Handling System or otherwise, even if Comergence is expressly advised of the possibility of such damages.
The Site’s content is copyrighted. Use of the Site’s content is prohibited except as provided herein, without the written permission of Comergence.
Although Comergence makes attempts to include accurate and up-to-date information in the Site, Comergence makes no warranties or representations as to its accuracy or timeliness. Comergence assumes no liability or responsibility for any errors or omissions in the content of the site. Information on this Site may contain technical inaccuracies or typographical errors. Comergence may change or update information without notice. Comergence may make improvements and/or changes in the products and/or programs described in this Site at any time without notice.
Use of and browsing in the Site are at User’s risk. Without limiting the foregoing or any outstanding agreements, everything on this Site is provided “As-Is” without warranty of any kind, either express or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose, or non-infringement. Some jurisdictions may not allow the exclusion of implied warranties; therefore some of the above exclusions may not apply.
Comergence either owns or has permission to use the images displayed on the Site. All of these images are either the property of, or used with permission by Comergence. All uses of these images are prohibited. Use of the images without authorization may violate certain laws, including, but not limited to those relating to copyright, trademark, privacy, and publicity.
These Legal Notices are subject to revision at any time by an update to this posting. Such revisions are binding upon any User of this Site. As a result, all Users should routinely visit this page to review the then current Legal Notices to which they are bound.
Comergence controls and operates this Site from its offices within the United States of America. Comergence makes no representation that materials in the Site are appropriate or available for use in other locations, and access to them from territories where there contents are illegal is prohibited. Those who choose to access this site from other locations do so on their own initiative and are responsible for compliance with applicable local laws. Any claim relating to the materials will be governed by the substantive laws of the State of California.