We take the privacy of your data seriously.

Valere Financial, a registered trade name of CrossCountry Mortgage, LLC (“Valere Financial”)

We value the trust you put in us and understand that protecting your personal information is critical to earning and keeping that trust. The California Consumer Privacy Act (CCPA) gives California residents the power to request to know, delete, and correct the personal info we have on file for them.

SUBMIT A CCPA REQUEST

or call  844-940-CCPA

CrossCountry Mortgage, LLC. is an Equal Housing Opportunity Lender. As prohibited by federal law, we do not engage in business practices that discriminate on the basis of race, color, religion, national origin, sex, marital status, age (provided you have the capacity to enter into a binding contract), because all or part of your income may be derived from any public assistance program, or because you have, in good faith, exercised any right under the Consumer Credit Protection Act. The federal agency that administers our compliance with these federal laws is the Federal Trade Commission, Equal Credit Opportunity, Washington, DC, 20580

California Consumer Privacy Act Disclosure

This California Consumer Privacy Act Disclosure (“Disclosure”) is meant to supplement the Valere Financial online Privacy Statement and explain how Valere Financial collects, uses, and discloses personal information relating to California residents covered by the California Consumer Privacy Act and its implementing regulations (“CCPA”). This Disclosure applies solely to visitors, users, applicants, and others who reside in the State of California (hereinafter referred to as a “consumer” or “consumers”). Any terms used in this Disclosure, but not defined herein, have the same definition as used in the CCPA

Background
The CCPA applies to consumers’ personal information, or information that identifies, relates to, or could be reasonably linked, directly or indirectly, with a California resident. Consumers’ personal information does not include information subject to the Gramm-Leach-Bliley Act (“GLBA”). Information subject to GLBA includes, without limitation: information provided to Valere Financial during the mortgage application process, information that results from the mortgage transaction; or, information Valere Financial otherwise obtains in connection with providing the mortgage.

The personal information Valere Financial collects, uses, and discloses varies based upon the relationship and/or interactions with an individual. For example, personal information collected from a consumer who visits the Valere Financial website and submits a mortgage application online may differ from personal information collected from a consumer who does business with Valere Financial in-person.

Information Collected

Valere Financial collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device. Valere Financial may collect the following categories of personal information from consumers. Categories of personal information collected in the last twelve (12) months are indicated by the term ‘YES’ in the ‘Collected’ column:

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (CA Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
F. Internet or similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements.	YES
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment related information	Current or past job history or performance evaluations.	YES

Valere Financial will only retain personal information for the length of time needed to fulfill the purpose for which it was collected.

Collection Sources

Valere Financial obtains the categories of personal information listed above from the following categories of sources:

• Directly from consumers or their agents. For example, from a consumer’s real estate agent prior to the consumer initiating a mortgage loan application.
• Directly and indirectly from activity on our website (www.valerefinancial.com). For example, a consumer’s IP address, kind of web browser and computer used, and locality including the state or country from which the consumer accessed the site.
• From service providers, consumer data resellers and other third parties that interact with us in connection with the services we perform. For example, from an entity that collects consumer personal information and then sells that information to Valere Financial as a lead.
• Public record sources including Federal, state or local government.

Use of Personal Information

Valere Financial may collect or disclose consumer personal information for one or more of the following business purposes:

• To fulfill or meet the reason for which the consumer provides the information. For example, if a consumer provides information to a loan officer, Valere Financial will use that information to assist in the preparation and submission of a loan application.
• To provide consumers with information including loan products and pricing.
• To provide consumers with email alerts or other notices concerning our products, services, events, or news that may be of interest.
• To carry out our obligations and enforce our rights arising from any contracts entered between consumers and Valere Financial, including for billing and collections.
• To improve the Valere Financial website and better present content to consumers. For example, auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of Valere Financial and our consumers or others. For example, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To establish or defend legal claims and allegations.
• To seek advice from attorneys, auditors and other professional advisors.
• As described to consumers in any notice provided at or before the time of collection of personal information, or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Valere Financial is among the assets transferred, or personal information held by Valere Financial is used to assess assets or personal information held by another.

Note: : Valere Financial will not collect additional categories of personal information or use the collected personal information for materially different, unrelated, or incompatible purposes without providing notice to consumers.

Disclosing Personal Information

Valere Financial has disclosed the following categories of personal information to third parties for a business purpose in the previous twelve (12) months:

• A. Identifiers
• B. Personal information categories
• C. Protected classification characteristics
• D. Commercial information
• E.Biometric Information
• F.Internet or similar network activity;
• G. Geolocation data
• H. Sensory data
• I. Professional or employment related information

Valere Financial has disclosed each of these categories of consumer personal information for business purposes to the following categories of third parties:

Category	Category of Third Party Information Provided To
A. Identifiers	Service Providers, Vendors, or Contractors. Technology Providers. Government, Regulatory, and Legal Entities.
B. Personal information categories listed in the California Customer Records statute (CA Civ. Code § 1798.80(e)).	Service Providers, Vendors, or Contractors. Technology Providers. Government, Regulatory, and Legal Entities.
C. Protected classification characteristics under California or federal law.	Service Providers, Vendors, or Contractors. Government, Regulatory, and Legal Entities.
D. Commercial information	Service Providers, Vendors, or Contractors. Government, Regulatory, and Legal Entities.
E. Biometric Information	Service Providers, Vendors, or Contractors. Technology Providers.
F. Internet or similar network activity	Service Providers, Vendors, or Contractors. Technology Providers. Government, Regulatory, and Legal Entities.
G. Geolocation data	Service Providers, Vendors, or Contractors. Technology Providers. Government, Regulatory, and Legal Entities.
H. Sensory data	Service Providers, Vendors, or Contractors. Technology Providers. Government, Regulatory, and Legal Entities.
I. Professional or employment related information	Service Providers, Vendors, or Contractors. Technology Providers. Government, Regulatory, and Legal Entities.

Sale and Sharing of Personal Information

Valere Financial has not shared personal information subject to the CCPA in the last twelve (12) months.

Valere Financial has sold the following categories of personal information to third parties in the previous twelve (12) months:

Category	Category of Third Party Information Sold To
A. Identifiers	Marketing and Analytics Companies
F. Internet or similar network activity	Marketing and Analytics Companies
G. Geolocation data	Marketing and Analytics Companies

Valere Financial may sell consumer personal information to third parties for one or more of the following commercial purposes:

• To market our products and services to California consumers.

Sensitive Personal Information

Valere Financial does not use or disclose sensitive personal information other than:

• To provide the products and services requested by you.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• To perform services on behalf of CrossCountry.
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Sale or Sharing of Personal Information of Minors

Valere Financial does not knowingly collect, sell, share, or disclose the personal information of a person less than 16 years of age.

Consumer Rights and Choices Under CCPA

The CCPA provides California residents with specific rights regarding their personal information. This section describes consumers’ CCPA rights and explains how to exercise those rights.

Right to Know/Right to Access Personal Information

California consumers have the right to request that Valere Financial disclose certain information about the collection and use of personal. Before Valere Financial discloses information, it will ask for information to verify the requestors identity. Once Valere Financial receives and confirms a verifiable consumer request, we will disclose the following:

• The categories of personal information Valere Financial collected about the consumer.
• The categories of sources from which Valere Financial collected the personal information;
• The business or commercial purpose for which Valere Financial collected, sold, or shared the information;
• The categories of third parties to whom Valere Financial disclosed the category of personal information for a business purpose;
• The categories of personal information that Valere Financial sold or shared and the categories of third parties to whom the personal information was sold or shared.
• The categories of personal information of the consumer that Valere Financial disclosed for a business purpose and the categories of persons to whom the personal information disclosed.

Additionally, if a consumer requests specific pieces of personal information collected by Valere Financial and provides the requested identifying information, Valere Financial will disclose the specific pieces of personal information to the requestor.

Note: Valere Financial may not disclose the requested information if it cannot verify a requestor’s identity. Valere Financial may not disclose certain information covered by one or more exemptions from the CCPA, as discussed earlier in this Disclosure. Under no circumstances will Valere Financial disclose a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.

Deletion Request Rights

Consumers may request the deletion of personal information collected and retained by Valere Financial. Upon receipt and confirmation of a verifiable consumer request, Valere Financial will delete (and/or direct Valere Financial service providers to delete) consumer personal information from applicable records, unless an exception applies. If Valere Financial denies a consumer deletion request, it will inform the consumer and explain the basis for the denial.

Correction Request Rights 

Consumers may request the correction of inaccurate personal information collected and retained by Valere Financial. Upon receipt and confirmation of a verifiable consumer request and supporting documentation (if necessary), Valere Financial will correct (and/or direct Valere Financial service providers to correct) the inaccurate consumer personal information in all applicable records, unless an exception applies. Valere Financial will inform the consumer whether it has complied with a consumer correction request. A consumer’s request to correct may be denied if Valere Financial determines that the contested information maintained by Valere Financial is more likely than not accurate based on the totality of relevant circumstances. If Valere Financial denies a consumer correction request, it will inform the consumer and explain the basis for the denial.

Right to Opt-Out of Selling or Sharing 
Valere Financial does not share California consumer personal information as defined in the CCPA.

Consumers may opt-out of the sale of their personal information collected by Valere Financial. Upon receipt of a consumer request Valere Financial will stop selling the consumer's non-exempt personal information to third parties as soon as feasibly possible, but no later than 15 business days from the date the Valere Financial receives the request. Valere Financial will also notify all third parties to whom Valere Financial has sold the consumer's personal information, that the consumer has made a request to opt-out of sale of their personal information and will direct them to comply with the consumer's request and forward the request to any other person to whom the third party has made the personal information available during that time period.

Non-Discrimination Rights

VValere Financial will not discriminate against any California resident, including consumers, employees, applicants, or independent contractors, for exercising any CCPA rights. Except to the extent permitted by the CCPA, Valere Financial will not:

• Deny you goods or services;
• Charge different prices or rates for goods or services based upon provision of personal information, including through granting discounts or other benefits, or imposing penalties;
• Provide different levels or quality of goods or services; or,
• Suggest that a consumer may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Rights

A consumer may exercise the rights described above by submitting a request to Valere Financial by either:

• Calling us at 844-940-CCPA (2272)
• Completing the online webform - California Privacy Request or
• For Requests to Opt-Out of the Sale of Personal Information – click on the “Do Not Sell or Share My Personal Information” button found in the banner at the bottom of this webpage.

A consumer must describe the request with enough detail so that Valere Financial may properly understand, evaluate, and respond to the request. A consumer may request to know and access personal information no more than twice within any 12-month period.

Other than for a request to opt-out of the sale of personal information, Valere Financial will respond only to requests that are verifiable consumer requests. As a result, Valere Financial will seek to verify a consumer’s identity upon receipt of any request. Valere Financial will ask information from the requestor that enables identification, such as the consumer’s email address or the last four digits of the consumer’s social security number. Valere Financial also may use a third-party verification provider to verify a consumer’s identity.

Correction Request: : As part of a request to correct inaccurate information that Valere Financial maintains about a consumer, the consumer submitting the request must provide any documentation that rebuts the accuracy of the contested information maintained by Valere Financial.

Authorized Agents: An authorized person may submit a CCPA request on behalf of a consumer using the telephone number or online webform shown above. An authorized agent will be required to provide their contact information, the verification information of the consumer on whose behalf they are making the CCPA request, any documentary evidence as part of a correction request, and to submit evidence of authorization to act on behalf of the consumer in the form of either:

• A document signed by the signed by the consumer giving the authorized agent permission to act on behalf of the consumer (CCM may also contact the consumer directly to verify their identity and that authorization has been given)
• A power of attorney pursuant to Probate Code sections 4121 to 4130

Valere Financial cannot respond to a request or provide a consumer with personal information if it cannot verify the identity of the consumer, the authority of a third party to make the request, and/or confirm the requested personal information relates to the consumer. Making a request does not require the creation of an account with Valere Financial. Valere Financial will only use personal information provided in a request to verify the requestor's identity or authority to make the request.

Response Timing and Format

Valere Financial strives to respond to each verifiable consumer request within 45 days of its receipt. If Valere Financial requires more time, it will inform the requestor of the reason and extension period in writing. If the requestor has a pre-existing account with Valere Financial, Valere Financial may deliver its written response by means of that account. If the requestor does not have a pre-existing account, Valere Financial may deliver its written response either by mail or electronically. For request to know and access personal information requests, Valere Financial will select a format to provide a consumer’s personal information that is readily useable and allows the consumer to transmit the information from one entity to another entity without hindrance.

Valere Financial does not charge a fee to process or respond to a verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded. If Valere Financial determines a request warrants a fee, Valere Financial will inform the consumer of the decision and provide a cost estimate before completing the request.

Request to Opt-Out of Selling - Valere Financial will stop selling the consumer’s personal information and will direct any applicable third parties to comply with the consumer's request and forward the request on to any additional applicable third parties as soon as feasible but no later than 15 business days from the date the Valere Financial receives the request.

Changes to This Disclosure

Valere Financial reserves the right to amend this Disclosure at its discretion and at any time. When Valere Financial makes changes to this Disclosure, it will notify consumers by posting a link to the updated Disclosure to its website homepage. Consumers should check back periodically for any updates.

How to Contact Us

For questions or comments about this Disclosure, our Privacy Statement, the ways in Valere Financial collects and uses consumer personal information, consumer choices and rights regarding such use, or exercising rights under California law, please contact Valere Financial at:

Phone: 844-940-CCPA (2272)
US Mail: Valere Financial Mortgage, LLC
Attn: Marketing Compliance Manager
2160 Superior Avenue
Cleveland, OH 44114

Or please contact CrossCountry by sending an email to: [email protected]

This policy was last updated on 03/07/2024