- Service Service means the website and the mobile application operated by The Christian Penner Mortgage Team
- Personal Data Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Cookies Cookies are small files stored on your device (computer or mobile device).
- Data Processors (or Service Providers) Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject (or User) Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by contacting us.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service. You can enable or disable location services when you use our Service at any time by way of your device settings.
Tracking & Cookies Data
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
- Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
Use of Data
The Christian Penner Mortgage Team uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law
Retention of Data
Transfer of Data
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, The Christian Penner Mortgage Team may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Christian Penner Mortgage Team may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of The Christian Penner Mortgage Team
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. The Christian Penner Mortgage Team aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where The Christian Penner Mortgage Team relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Third Party Applications
We may use third-party Service Providers to monitor and analyze the use of our Service.
- Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
- Google AdWords Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/adsGoogle also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
- Facebook Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Links to Other Sites
Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Notwithstanding any current or prior election to opt in or opt out of receiving telemarketing calls or SMS messages (including text messages) from us, our agents, representatives, affiliates, or anyone calling on our behalf, you expressly consent to be contacted by us, our agents, representatives, affiliates, or anyone calling on our behalf for any and all purposes arising out of or relating to your loan and/or account, at any telephone number, or physical or electronic address you provide or at which you may be reached. You agree we may contact you in any way, including SMS messages (including text messages), calls using prerecorded messages or artificial voice, and calls and messages delivered using auto telephone dialing system, ringless voicemail system or an automatic texting system. Automated messages may be played when the telephone is answered, whether by you or someone else. In the event that an agent or representative calls, he or she may also leave a message on your answering machine, voice mail, or send one via text. You consent to receive SMS messages (including text messages), calls and messages (including prerecorded and artificial voice and autodialed) from us, our agents, representatives, affiliates or anyone calling on our behalf at the specific number(s) you have provided to us, or numbers we can reasonably associate with your account (through skip trace, caller ID capture or other means), with information or questions about your application, loan and/or account. You certify, warrant and represent that the telephone numbers that you have provided to us are your contact numbers. You represent that you are permitted and consent to receive calls at each of the telephone numbers you have provided to us. You agree to promptly alert us whenever you stop using a particular telephone number. Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You also agree that we may contact you by e-mail, using any email address you have provided to us or that you provide to us in the future. We may listen to and/or record phone calls between you and our representatives without notice to you as permitted by applicable law. For example, we listen to and record calls for quality monitoring purposes. To ensure that consumer’s inquiries are handled promptly, courteously, and accurately, some of the phone calls between you and us or any of our affiliates, agents, assigns and service providers, may be monitored and recorded by us and any of our affiliates, agents, assigns and service providers, to enhance service to you. You consent to this monitoring and recording. You agree that Christian Penner and/or The Christian Penner Mortgage Team (“us”, “we”, or “our”) may from time to time make calls and/or send text messages to you at any telephone number associated with your account, including wireless telephone numbers that could result in charges to you. The manner in which these calls or text messages are made to you may include, but is not limited to, the use of prerecorded/artificial voice messages and/or automatic telephone dialing system. You further agree that Christian Penner and/or The Christian Penner Mortgage Team (“us”, “we”, or “our”) may send e-mails to you at any e-mail address you provide us or use other electronic means of communication to the extent permitted by law. Consent may be revoked at any time and by any reasonable means.
CONSENT FOR SMS/TEXTING
At ChristianPenner.com, we take online privacy seriously. We are committed to protect personal information of our website and social media visitors. Our goal is to maintain your trust when handling your personal financial information. The ChristianPenner.com Privacy Options applies to your interaction with Christianpenner.com or any of its subsidiaries (Christian Penner and/or The Christian Penner Mortgage Team (“us”, “we”, or “our”), at any online or mobile site or application that we own or control (“Site”). According to the U.S. Online & Mobile Privacy Practices Statement, ChristianPenner.com’s online and mobile privacy practices are applicable to ChristianPenner.com websites, ChristianPenner.com mobile sites, and ChristianPenner.com branded social media sites or pages, as well as interactions you may have while viewing content provided by ChristianPenner.com’s digital advertising campaigns.
- ChristianPenner.com’s services are intended for U.S. customers.
- Our services are not intended for people under 18. Therefore, we do not knowingly collect information from people under 18 without parental consent.
- We share information we collect from or about you in accordance with our Consumer Privacy Notice, if you have a financial product or service with us.
AGREEMENTS TO PRIVACY OPTIONS
By using a Site or engaging with a ChristianPenner.com, Christian Penner and/or The Christian Penner Mortgage Team (“us”, “we”, or “our”) advertisement or page or account on a third party site, you consent to these Privacy Options, which includes your consent to our use and disclosure of information about you in the manner described in the Privacy Options.
PERSONAL INFORMATION COLLECTED ONLINE BY CHRISTIANPENNER.COM
When you visit our Sites, we collect personal information about you, from the information you provide us. The information will vary depend on the ChristianPenner.com Site you visit, and may include, but is not limited to:
- Date of birth
- Phone numbers (including mobile)
- Email address
- Account number
- Social Security number in whole or in part
- Residential information
- Employment information
- Income information
OUR SOCIAL MEDIA PAGES
ChristianPenner.com has official pages on social media websites such as Facebook®, Google+, Twitter®, Pinterest, LinkedIn, Instagram, and YouTube. When you interact with us on social media websites, we may collect behavioral information such as your likes, interests, feedback and preferences.
HOW INFORMATION IS USED
- To enable you to apply for ChristianPenner.com services
- To enable you to perform online transactions
- To update you about your account
- To service and manage your account
- To offer special services and products using advertisements in the form of banner ads, splash ads or location-based promotions Verification purposes that will allow access to your accounts and prevent/detect fraud
- For business purposes such as data analysis and optimizing Sites to improve your online experience
- In order to comply with federal, state or local laws
- To share with entities that are within the ChristianPenner.com family, and with trusted parties who are contractually obligated to keep such information confidential and only provide services that we have requested them to provide
DISCLOSURE OF INFORMATION
We may share information about you with our affiliates and other third parties:
- Third-party service providers
- When laws and regulations permit, with affiliated websites and businesses
- Other companies bringing you co-branded services
- Other third parties, to comply with legal requirements
Depending on the information, we or our affiliates, service providers and other companies that we work with have about you, you will see advertisements when you are using our online services (including pre-screened offers of credit). Online behavioral advertising (OBA or “interested-based advertising”) is practiced by collecting information about how visitors interact with our Sites over time, in order to deliver advertisements that may interest visitors based on their browsing history.
- By email: TheMortgageTeam@ChristianPenner.com
- By visiting this page on our website: https://christianpenner.com/#contact