Privacy Policy

1. Information We Collect

We collect information to provide better services to our users. The types of information we collect include:

1.1. Information You Provide Directly

• Contact Information: Name, address, phone number, email address, and other contact details.
• Application Data: Information you provide when applying for a mortgage, such as employment, income, financial, and credit information.
• Communications: Records of your correspondence with us, including via email, phone, text, or through our website forms.
• Payment Information: If applicable, payment card details or bank account information for processing transactions.

1.2. Information Collected Automatically

• Log Data: IP address, browser type, operating system, access times, and referring website addresses.
• Usage Data: Information about your use of the Site, including pages viewed, links clicked, and other actions.
• Cookies & Similar Technologies: We use cookies and related technologies to recognize you and customize your experience (see Section 5).
• Device Information: Information about the device you use to access our Site, including hardware model, operating system, and mobile network information.

1.3. Information from AI-Powered Communications

We may collect, record, or transcribe information exchanged via AI-powered text messages, phone calls, emails, or chatbots. These communications may include personal information you provide during interactions with our automated systems.

1.4. Information from Third Parties

We may receive information about you from third parties, such as credit bureaus, identity verification services, and other service providers necessary for processing your mortgage application.

2. How We Use Your Information

We use your information for purposes including, but not limited to:

• Processing Applications: To process and evaluate your mortgage application or other service requests.
• Communications: To contact you about your application, account, or other inquiries, including through AI-powered or automated systems (see Section 6).
• Personalization: To personalize your experience and deliver relevant content, services, and offers.
• Improvement: To improve our Site, products, and services, including training and enhancing our AI systems.
• Compliance: To comply with legal and regulatory requirements and respond to lawful requests or legal processes.
• Security: To detect, prevent, and address technical issues, fraud, or other misuse.
• Marketing: To send you promotional materials and information about our products and services, subject to your consent where required by law.
• Analytics: To analyze trends, administer the Site, track user movements, and gather demographic information.

3. How We Share Your Information

We may share your information as follows:

• With Service Providers: With trusted service providers who assist us in operating our Site, processing applications, or providing other services on our behalf (including providers of AI communications technology). These providers are contractually obligated to protect your information.
• With Financial Institutions: With lenders, investors, and other financial institutions involved in processing your mortgage application or loan.
• Legal Requirements: As required by law, regulation, legal process, or governmental request.
• Business Transfers: In connection with a merger, acquisition, sale of assets, or similar business transfer.
• With Your Consent: With other parties at your direction or with your explicit consent.
• To Protect Rights: When we believe disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

We do not sell your personal information to third parties for marketing purposes.

4. Data Security

We implement appropriate technical and organizational measures to protect your information from unauthorized access, use, alteration, or disclosure. These measures include:

• Encryption of sensitive data during transmission and storage
• Regular security assessments and updates
• Access controls and authentication procedures
• Employee training on data protection practices

Despite these efforts, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience, analyze usage, and deliver personalized content. Types of cookies we use include:

• Essential Cookies: Required for the Site to function properly
• Performance Cookies: Help us understand how visitors interact with our Site
• Functionality Cookies: Remember your preferences and settings
• Targeting Cookies: Used to deliver relevant advertisements

You can manage your cookie preferences through your browser settings. Disabling cookies may affect your ability to use certain features of our Site.

6. AI-Powered Communications

6.1. Nature of Automated Contact

By providing your contact information, you agree that Home First Mortgage may contact you via AI-powered or automated systems, including text messages, phone calls (which may use prerecorded or AI-generated voices), and email.

6.2. Transparency and Opt-Out

Automated communications will identify themselves as such. You may opt out of receiving AI-powered or automated communications at any time by following the opt-out instructions in the message (e.g., replying "STOP" to a text) or by contacting us at team.ie@homefirst.digital.

6.3. Data from AI Interactions

Data collected from AI-powered communications may be used for customer service, application processing, quality assurance, and service improvement. We retain this data in accordance with our data retention policies and applicable law.

7. Your Choices and Rights

Depending on your location, you may have certain rights regarding your personal information:

• Access and Correction: You may request access to or correction of your personal information by contacting us.
• Deletion: You may request deletion of your personal information, subject to certain exceptions required by law.
• Opt-Out: You may opt out of marketing communications or AI-powered communications at any time.
• Cookies: You can manage cookies via your browser settings.
• Do Not Track: Our Site does not currently respond to "Do Not Track" browser signals.
• Data Portability: You may request a copy of your personal information in a portable format.
• Restrict Processing: You may request that we restrict the processing of your personal information in certain circumstances.

To exercise any of these rights, please contact us at team.ie@homefirst.digital. We will respond to your request within a reasonable timeframe as required by applicable law.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining retention periods, we consider factors such as the nature of the information, legal and regulatory requirements, and our legitimate business needs.

9. Children's Privacy

Our Site is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information.

10. Third-Party Links

Our Site may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

11. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information we collect, use, disclose, and sell
• Right to request deletion of your personal information
• Right to opt-out of the sale of your personal information (we do not sell personal information)
• Right to non-discrimination for exercising your CCPA rights

To exercise these rights, please contact us at team.ie@homefirst.digital.

12. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those of your country. We take appropriate measures to ensure that your personal information remains protected in accordance with this Privacy Policy.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically. Your continued use of the Site after any changes indicates your acceptance of the updated Privacy Policy.

14. Gramm-Leach-Bliley Act (GLBA) Compliance

As a financial institution, we comply with the Gramm-Leach-Bliley Act and its implementing regulations. We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information. We limit access to your information to those employees and service providers who need it to provide products and services to you.