Legal

Haven Servicing Privacy Policy

Last updated September 28, 2023

Introduction

Haven Servicing, Inc. (“Company,” “we,” or “us”) provides technology solutions to mortgage lenders, loan servicers, subservicers, and real estate brokerages (“Mortgage Companies”) to improve the homeownership experience for their consumers. When you interact with Haven software, you are also interacting with us in our capacity as a software service provider to the Mortgage Company with whom you have an existing relationship. Haven is not a servicer, lender, realtor, or loan broker, and does not make lending or credit decisions.

We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you access to and use of our white-labeled or Haven branded portal, and all other products and services offered by Haven, including any content, applications, functionality, and services offered on or through our website, either directly or through our customers (the “Platform”). This policy also describes our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

As a result of your use of and access to our Platform, i.e. our white-labeled or Haven branded portal, and all other products and services offered by Haven, including any content, applications, functionality, and services offered on or through https://www.havenservicing.com.
In email, text, and other electronic messages between you and our Platform.
Through mobile and desktop applications you access from this website, which provide dedicated non-browser-based or browser-based interaction between you and our Platform.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Platform.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using this Platform, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Platform. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Platform or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at: privacy@havenservicing.com

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Platform, including information:

Basic details: Your name, address, email, IP address, among other common identifiers.
Transactional history: Information about your transactions, personal property, and buying habits.
Financial background: Pieces of your financial history related to home financing and other relevant financial information.
Online activity: Your browsing history and other device or network-related data.
Location info: General location information based on your IP address or location information provided by you.
Work history: Professional and employment-related information you share with us.
Demographics: Information like your marital status, as protected by law.
Personalized profiles: Our understanding of your preferences and behavior based on your use of our platform.

We collect this information in the following ways:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
From third parties, for example, your Mortgage Company or our business partners.
If you sign up for, or log into, Haven using a third-party platform like Facebook or Google, we may receive information about you from such third-party platforms.
Through our Application Programming Interface (API) connections with third parties to provide you with our Services.

Information You Provide to Us.

The information we collect on or through our Platform may include:

Information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Platform.
Records and copies of your correspondence (including email addresses), if you contact us.
Details of transactions you carry out through our Platform and of the fulfillment of your orders. You may be required to provide financial information before placing an order or completing an application through our Platform (e.g. completing an application or pre-approval application for a financial product or service, such as a mortgage or an insurance product).
Details of your use of our Platform, including your interaction with all applications and services offered by our Platform.
Information about your financial history, with your consent, including loan-level information, AVM home value, payment history, tax and insurance about your properties, documents associated with your loan, credit score and credit history, bank account details, and offers.
Information related to the ways in which you interact with the Platform, such as mouse movements and scrolling, referring and exit web pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Platform, amount of time spent on particular pages, date and time you used the Platform, frequency of your use of the Platform, error logs, and other similar information.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Platform according to your individual interests.
Speed up your searches.
Recognize you when you return to our Platform.
Record certain information about your sessions on our Platform.
Allow opting out of usage of tracking cookies.
Better secure our Platform and services.
To improve upon our services.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
Analytics Software such as Heap Analytics and Google Analytics to collect data of the use of our Platform and services.
We also use a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Our service provider stores this information on our behalf in a pseudonymized user profile and they are contractually forbidden to sell any of the data collected on our behalf.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To provide services through or in connection with the Platform to your Mortgage Company, and to you on behalf of your Mortgage Company, including:
- To present our Platform and its contents to you.
- To provide you with information, products, or services that you request.
- To market products and services we believe may be of interest to you.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Platform or any products or services we offer or provide through it.
- To allow you to participate in interactive features on our Platform.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
- To provide analytics and reporting services to your Mortgage Company.
- To verify your identity, including authentication based on applicable account information.
- Sending you communications on behalf of your Mortgage Company related to your Platform activities;
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; and
Responding to legal requests and demands, as well as exercising and defending legal claims.
For internal purposes to improve our services, including:
- Undertaking internal research and reporting; and
- For development, such as to improve the content and features of the Platform.

We may also collect, use, and disclose your information in an anonymized and aggregated, or de-identified form (that does not identify you personally) for our business purposes.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose anonymized and aggregated, or otherwise de-identified information about our users without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To your Mortgage Company. We may disclose the information you provide with, or make that information available to your Mortgage Company, its successors-in-interest, and other relevant third parties that your Mortgage Company has authorized to access the information in order to facilitate the ongoing servicing of your loan or other financial services, and provide related services and products to you. If you have questions about your Mortgage Company’s privacy practices, please contact your Mortgage Company directly. Haven is not responsible for the privacy practices of your Mortgage Company.
To third parties, for marketing and advertising purposes, in order to tailor content in your marketplace and on the Platform.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Haven Servicing, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Haven Servicing, Inc. about our Platform users is among the assets transferred.
With your consent or authorization or on behalf of your Mortgage Company, we may disclose information we collect with third parties to market their products or services to you or to deliver products and services to you.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Haven Servicing, Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. Occasionally we share your information with third parties in order to tailor content in your marketplace and on the Platform. Otherwise, we’ll only disclose your information with unaffiliated third-parties for their marketing purposes when you have consented to the sharing. You can opt out by going to the “Do Not Sell or Share My Information” link on the Platform or by sending us an email stating your request to privacy@havenservicing.com. To address what these unaffiliated third-parties do with your data once you have consented to the sharing, please contact the third-party to learn more about your choices.
Email Promotional Offers from Haven. If you do not wish to have your email address used by Haven to promote our own or third parties’ products or services, you can opt out by logging into your Platform account and navigating to your account settings & preferences, or by sending us an email stating your request to privacy@havenservicing.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link in the email or by sending us a return email asking to be omitted from future email distributions.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@havenservicing.com.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Platform and visiting your account settings & preferences. When you update information, however, we may maintain a copy of the unrevised information in our records to the extent necessary for legal compliance purposes and where permitted by applicable law. Any information that cannot be updated or edited through the Platform will require you to contact your Mortgage Company for further assistance. Additionally, to the extent applicable law affords you rights regarding personal information held by your Mortgage Company, such as access and deletion rights, please reach out to your Mortgage Company to inquire about your data rights.

You may also send us an email at privacy@havenservicing.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see “Haven Servicing Inc. Privacy Policy for California Residents” below.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and traffic to and from our Platform and services will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

Changes to Our Privacy Policy

If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Platform home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@havenservicing.com

Haven Servicing Inc. Privacy Policy for California Residents

Updated Sept 28, 2023

This Privacy Policy for California Residents supplements the information contained in Haven Servicing Inc.’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with California law, including but not limited to the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this policy.

California Shine the Light Statement:

California’s “shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@havenservicing.com or write us at: One Gateway Center, Suite 2600, Newark, New Jersey 07102.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

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 (Cal. 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 other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Device location by way of IP address.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES
L. Sensitive Personal Information	Account login information, biometric data, contents of email or text messages, debit or credit card numbers, precise geolocation, social security numbers, state id card numbers, drivers’ licenses, genetic data, health data, passport numbers, racial or ethnic origin, religious or philosophical beliefs, union membership and sex life or sexual orientation	YES

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
From third parties, for example, your Mortgage Company or our business partners.
Through our Application Programming Interface (API) connections with third parties

Our Retention of Personal Information

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. In determining the appropriate retention period, we will take into account the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, and the purposes for which we process your personal information. We will also take into account any applicable legal requirements, such as retention periods prescribed by law or regulation. We will securely delete your personal information when it is no longer needed for these purposes.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Platform, products, and services.
To create, maintain, customize, and secure your account with us.
To market products and services we believe may be of interest to you.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Platform, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, 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 us about our Platform users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sales or Sharing of Personal Information

This chart lists for the past twelve (12) months the categories of personal information we have sold or shared, the categories of third parties to whom we have sold or shared personal information and the specific business or commercial purpose for selling or sharing personal information. We have no actual knowledge of having sold or shared personal information of consumers under 16 years of age.

Category	Examples	Sold or Shared	Business or Commercial Purpose
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	YES	Advertising and marketing: We share information with our partners to tailor marketplace content and offerings.
B. Personal information categories listed in the California Customer Records statute (Cal. 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	Advertising and marketing: We share information with our partners to tailor marketplace content and offerings.
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).	NO	N/A
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	Advertising and marketing: We share information with our partners to tailor marketplace content and offerings.
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.	NO	N/A
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO	N/A
G. Geolocation data.	Device location by way of IP address.	NO	N/A
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	N/A	N/A
I. Professional or employment-related information.	Current or past job history or performance evaluations.	N/A	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	N/A	N/A
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	N/A	N/A
L. Sensitive Personal Information	Account login information, biometric data, contents of email or text messages, debit or credit card numbers, precise geolocation, social security numbers, state id card numbers, drivers’ licenses, genetic data, health data, passport numbers, racial or ethnic origin, religious or philosophical beliefs, union membership and sex life or sexual orientation	NO

Disclosing Personal Information

We may disclose your personal information by sending it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.
Service providers.
Third parties to whom you or your Mortgage Company authorizes us to disclose your personal information in connection with products or services they provide to you.

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

Category	Examples	Disclosed
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 (Cal. 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).	NO
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.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Device location by way of IP address.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	N/A
I. Professional or employment-related information.	Current or past job history or performance evaluations.	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	N/A
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	N/A
L. Sensitive Personal Information	Account login information, biometric data, contents of email or text messages, debit or credit card numbers, precise geolocation, social security numbers, state id card numbers, drivers’ licenses, genetic data, health data, passport numbers, racial or ethnic origin, religious or philosophical beliefs, union membership and sex life or sexual orientation	NO

Your Rights and Choices

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

Please note we are not the controlling business for some of the personal information maintained on our systems, and we may direct you to your Mortgage Company based on the type and content of the request you make. Additionally, these rights are subject to many exemptions and exceptions under California law, in which case we may deny your requests in whole or in part.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we disclose that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Please note we are not the controlling business for some of the personal information maintained on our systems, and we may direct you to your Mortgage Company in the event you request to delete this information.

Right to Opt-Out of Targeted Advertising from “Sharing”

You can opt out by going to the “Do Not Sell or Share My Information” link or by sending us an email stating your request to privacy@havenservicing.com.

Please note we are not the controlling business for some of the personal information maintained on our systems, and we may direct you to your Mortgage Company in the event your opt-out request pertains to their data processing practices.

Right to Opt-Out of Sales of Your Personal Information

You can opt out by going to the “Do Not Sell or Share My Information” link, or by sending us an email stating your request to privacy@havenservicing.com.

Please note: we are not the controlling business for some of the personal information maintained on our systems, and we may direct you to your Mortgage Company in the event your opt-out request pertains to their data processing practices.

Exercising Your Rights

To exercise your rights described above, please submit a request by either:

Emailing us at privacy@havenservicing.com;
Using our data subjects rights form, available when you log in to the Platform; or
Clicking the “Do Not Sell or Share My Personal Information” when logged in to the Platform.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by emailing privacy@havenservicing.com.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Photo Identification
- Social Security Number
- Photo Identification of Parent or Guardian with Proof that they are Parent or Guardian of subject.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@havenservicing.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Financial Incentives

We do not offer any financial incentives, discounts, or other benefits in exchange for the collection, sale, or disclosure of your personal information, as contemplated under the CCPA and CPRA.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Haven collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: havenservicing.com

Email: prviacy@havenservicing.com

Postal Address:

Haven Servicing, Inc.

300 Main Street

Suite 21 #863

Madison, NJ 07940