Information Covered by this Policy
Our Policy covers all non-public, personal information received by us that may be used to identify you and as may be further defined by applicable privacy laws ("Personal Information"). This may include a wide variety of information, such as name and address information, social security, passport date of birth, or other identification numbers and banking information. We use these both to verify your identity and your financial eligibility for any loan you may receive with SIRVA Mortgage.
General Data Protection Regulation Information
When we are acting at the direction of a corporate client to provide services to you as part of your relocation or assignment, then the client is responsible as the Data Controller for telling us how your Personal Information should be used and processed. Under the European Union’s General Data Protection Regulation, SIRVA and its family of companies are Data Processors who receive Personal Information and instructions on how to process that Personal Information from the Data Controllers. Where we act as a Data Controller for services you independently request of us (i.e., where we independently determine how any Personal Information is processed), then we manage your Personal Information according to what you have consented to and the terms of this policy. Whether acting as a Data Controller or a Data Processor, we maintain the privacy of your information and only use, share, transfer or store it as permitted.
How We Obtain Personal Information
- You directly, when you complete an application or when you visit us in person, over the phone, through the mail, or through our website;
- Your transactions with any of the companies in the SIRVA family;
- Consumer reporting agencies;
- Mortgage, Title, appraisal or other companies connected with a financial product or service involved in the sale or purchase of your home;
- Your employer;
- Anyone who you have authorized to provide information; and
- Other sources, in connection with providing you a financial product or service.
Regardless of its source, SIRVA Mortgage will not process Personal Information without your consent.
Information Use, Sharing & Storage
Your personal information will be processed and retained as needed in connection with your application, and to provide you with our mortgageloan services. This may include a period of time after the services are complete in order to comply with our regulatory, audit, contractual, and other legal obligations.
A. Sharing within the SIRVA Family of Companies
To provide you with the full range of financial services you may need, SIRVA Mortgage takes an integrated approach to the services we provide. In order to be able to provide a full range of services for your needs and make recommendations about a variety of the services offered by and through SIRVA Mortgage and its family of affiliated companies, we may share Personal Information among the SIRVA family of companies.
B. Sharing with non-SIRVA Family Companies
To provide you with your mortgage services, SIRVA may work with and provide your information to companies outside of the SIRVA family to provide those services to you. For example, SIRVA may share Personal Information to:
- service and support our operations generally and to support your account and services that we provide to you, including proposed or actual financing, securitization, secondary market sale, or similar transactions;
- process or administer a transaction or product in connection with a product or transaction that you have requested;
- data storage and processing;
- those you have authorized us to disclose the information;
- other service providers with whom we have agreements to offer services to you through or with SIRVA; or
- other suppliers with which we jointly market or provide products or services.
We may also share your Personal Information with these other organizations outside of the SIRVA family when required by law. For example, we may share Personal Information to:
- protect against fraud;
- respond to a subpoena or summons; or
- respond to law enforcement or regulatory authorities.
We will not disclose your Personal Information to anyone outside of SIRVA unless you have authorized us to do so or as otherwise indicated in this Policy or as required by law.
We maintain agreements with our external service providers limiting the use of your Personal Information only for the purposes you have intended in providing the information. These service providers are bound to uphold our standards and procedures regarding privacy under the terms of our agreements with them.
Your Privacy Rights
SIRVA provides you with a reasonable opportunity to access your own Personal Information, to correct that information if inaccurate, or to have it deleted as appropriate--subject to the exceptions stated below.
firstname.lastname@example.org, or by telephone at (800) 531-3837.
For California Customers
California law provides consumers in California with additional rights over their Personal Information. If you are a customer in California, you also have rights to storage limitation and data minimization for any Personal Information that has been collected. This means that you may contact us to ask that we only collect or retain certain, essential Personal Information. You may also request that we remove your Personal Information from our systems after a specific amount of time, or after it is no longer needed for our business purposes (which may include a retention period as needed for our regulatory, audit, contractual, and other legal obligations).
As part of its routine business operations, SIRVA upholds the principle of data minimization by only collecting and processing Personal Information as absolutely necessary to provide services. Nevertheless, if you wish to opt out of any processing of your Personal Information, or wish to exercise either of the additional rights shown above, please contact us with your request via email at email@example.com or by telephone to the number (800) 531-3837. Your services may be impacted depending upon the nature of your request.
Data Integrity & Security
SIRVA will make every reasonable effort to keep Personal Information accurate while we are using that information to serve you. SIRVA appreciates your cooperation in maintaining complete and up-to-date Personal Information and will facilitate your efforts in this regard. SIRVA retains Personal Information for as long as we have determined it is needed for the purposes for which it was received or as required by contractual, record keeping, or other legal requirements.
We limit access to Personal Information about you to those employees who need to know that information to provide products and services to you. We do not sell your Personal Information.
We maintain physical, electronic, and procedural safeguards to protect your Personal Information. We regularly assess security standards and procedures to protect against unauthorized access to Personal Information.
We store your Personal Information on servers that may be located in various countries, but always in compliance with this policy and all applicable data privacy laws and regulations.
You should always safeguard your own Personal Information by protecting passwords used to access a SIRVA system and by safely disposing of records and reports no longer needed.
As and when required by law, SIRVA will notify and work with regulatory and/or law enforcement officials as required by law to address any issues or security breaches where they arise.
B. Dispute Resolution
SIRVA recognizes the importance of providing you the opportunity to address and resolve complaints about the processing of your Personal Information. Therefore, in addition to any legal remedies that may be available, if you make a complaint with us about the processing of your Personal Information and it is not resolved to your satisfaction internally at SIRVA, you may also file a complaint with the American Arbitration Association ("AAA") at the AAA website, located here, or seek its independent alternative dispute resolution services. The American Arbitration Association ("AAA") is also located at the following address:
225 North Michigan Avenue, Suite 2527
Chicago, Illinois 60601-7601 USA
The AAA can be reached by telephone at (312) 616-6560 or by facsimile at (312) 819-0404.