Initial and Annual Privacy Notice
DFM GROUP, LLC. ("DFM") is serious about protecting your online privacy and the information that you submit at the DFM website (the "Website"). This Privacy Policy explains our views and practices concerning privacy, and how they may pertain to you as a user of our system.
"You" or "Your" means you as a user of DFM services or of this Website. "We" or "Our" or "Us" means DFM GROUP, LLC.
All information transmitted, printed or otherwise submitted to DFM via this Website shall be deemed to be the property of DFM and DFM shall be free to use such information for any lawful purpose as detailed herein.
This Website may contain links to other web sites and if so we are not responsible for the privacy practices or the content of such other web sites.
Section 1
Collected Information
We automatically collect and/or track the following:
- Web page http headers (home server domain names, IP address, type of client computer, type of Web browser and operating system);
- Information knowingly provided by you through on-line forms, registration forms, surveys, and/or other entries, such as email addresses, Social Security Numbers, employment information and other personal, financial or demographic information;
- Information, user specific or aggregate, on what pages our visitors access and referring URLs; and
- The e-mail addresses of visitors that communicate with DFM via e-mail.
Please understand that the information that you submit to us at the Website is voluntary, but required for a loan or referral from our Website.
Section 2
Gramm-Leach-Bliley Act and California Financial Privacy Act Notice
For purposes of compliance with the Gramm-Leach-Bliley Financial Modernization Act of 1999, 15 U.S.C. 6802 (the "GLB Act") this Privacy Policy shall serve as both your initial customer relationship and annual "Privacy Notice" as defined under the GLB Act.
Section 3
Use of Data Collected
We use your personal, demographic and profile data to enhance your experience at our Website and to enable us to present content that we think you might be interested in. We use your contact information to send you information about our company and promotional material from our affiliates and partners. We may also use your personal, demographic and profile data to improve our Website, for statistical analysis, for marketing and promotional purposes, and for editorial or feedback purposes. Notwithstanding the foregoing, we will not share the Social Security Numbers of California State residents with third parties without first obtaining their consent to do so. Information collected by us may be added to our databases and used for future e-mails or postal mailings regarding site updates, new products and services, upcoming events, and/or status of orders placed online.
Section 4
Disclosure of Data to Third Parties
If you choose to provide personal information, it will be used for the following purposes: considering you for a DFM account, sharing of your information with trusted third parties such as credit bureaus, loan service providers and/or other financial services providers in accordance with the terms of the GLB Act, or as required by law; and for marketing products and services which we determine, in our sole judgment, that you might find of interest. We reserve the right to share, rent, sell, or otherwise disclose data we collect to third parties in accordance with the terms of the GLB Act. Any third party we share, rent, sell, or otherwise disclose data to will be prescreened by us, determined by us to be reputable, and will use the personal data for marketing products and services which we determine, in our sole judgment, that you might find of interest. These businesses may include, but are not limited to: providers of direct marketing services and providers, including lookup and reference, data enhancement, suppression and validation; e-mail marketers; SMS-text message marketers; and telemarketers. By using this site, you agree that you may be contacted in any manner contemplated in this section even if your number is found on a do not call registry, in-house list, or similar registry. We may also employ other companies and individuals to perform certain functions on our behalf. These agents have access to personal information as needed to perform their functions for DFM, but we do not permit them to use personal information for other purposes. For purposes of compliance with the CFPA, we will not share "nonpublic personal information." Any and all loan-specific financial information that we collect as part of your loan application (Social Security Number and employment information), and from third-parties (including, but not limited to, consumer reporting agencies, consumer credit bureaus and other outside parties as permitted or required by applicable laws) will be used to determine your eligibility for a loan and will not be shared with third-parties other than independent loan service providers for purposes of evaluating your qualifications for a loan and provision of such a loan, should you qualify. If you choose to provide information, such as your Social Security Number, we may use that information to determine your financial status. If you do not provide such information, we may also use other information that you provide for the purpose of verifying your eligibility for a loan or for any other programs, offer or services. Upon qualification, your ultimate loan-specific financial information will be stored and utilized by your specific lender pursuant to the terms of that lender's Privacy Policy.
DFM reserves the right to release current or past user information in the event DFM believes that the service and/or Website is being or has been used in violation of the Website Terms and Conditions, or to commit unlawful acts, if the information is subpoenaed, if DFM is sold or acquired, or whenever DFM deems it necessary or appropriate. By agreeing to these conditions, you hereby consent to disclosure of any record or communication to any third party, when DFM, in its sole discretion, determines the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and Federal Trade Commission enabling regulations.
In addition, by registering and/or using the Website, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR 310 et seq.), as amended from time to time (the "Rule"). Notwithstanding that your telephone number may be listed at the Federal Trade Commission’s Do-Not-Call List, we retain the right to contact you via telemarketing in accordance with the Rule.
Section 5
Information Collection Processes
DFM may employ "cookies" to help customize your access to the Website. A cookie is a piece of data stored on your hard drive containing information about you. Cookies have many benefits to enhance your experience at our Website. For instance, by setting a cookie on our Website, a user would not have to log in a password more than once, thereby saving time while on our Website. Even in the case where a user rejects a cookie, they may still use our Website.
We occasionally use cookies to anonymously track and target the interests of our users to further enhance the experience on our Website or for advertising tracking purposes.
In addition to cookies, our Website pages and/or e-mails may contain electronic images know as "pixel tags" (also knows as clear gifs) to track the pages that visitors and/or users visit at the Website for purposes of formatting future campaigns and upgrading visitor information used in reporting statistics. Our Website may also contain pixel tags placed there by third parties to help determine the effectiveness of a joint promotional or advertising campaign.
Section 6
Your Opt-Out Rights
You may opt-out of receiving marketing communications from us and/or our partners by choosing not to submit your information. We also allow you to remove your information from our marketing lists. If you remove your information from our marketing lists it will no longer be used by us for secondary purposes. You can opt-out by logging into your account and un-checking the option to receive marketing communications in your account settings.
Section 7
We Do Not Intend to Collect Data from Children
Individuals under eighteen (18) years of age are not permitted to obtain products and/or services from DFM. No information should be submitted to, or posted at, DFM by visitors under eighteen (18) years of age without first obtaining the prior consent of their parent or guardian.
Section 8
Our Right to Contact You
We reserve the right to contact you regarding your account status and changes to customer agreements, Privacy Policy, or any other policies or agreements relevant to you.
Section 9
Security
Although we take reasonable technological precaution to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Any transmission of data at or through our Website is at your own risk. However, access to your information is strictly limited, and not accessible to the public. Our employees are dedicated to ensuring the security and privacy of all DFM user information. Employees not adhering to our firm policies are subject to disciplinary action.
Section 10
Our Right to Change
We reserve the right to change this policy at any time by notifying you of the existence and location of the new or revised privacy policy or by posting the changes online at our Website. All changes will take effect immediately upon their posting on our Website. Please check this page periodically for changes. Your continued use of the DFM service, website or acceptance of our e-mails following the posting of changes to this Policy will mean that you accept any and all such changes and that you agree to continue receiving direct marketing from us and other third party companies.
Section 11
From time to time, DFM will enter into an arrangement with a third party website to allow individuals to opt into our marketing program on those third party websites. In each case, the third party websites have represented and warranted to us, among other things, that the data was collected voluntarily from individuals on website registrations and co-registrations, that the sellers have a right, under any applicable privacy statements, to transfer the data to us, and that DFM has the right to send marketing offers to the individuals. We hope this information satisfies any questions or concerns you may have regarding the email practices of DFM. If you have additional questions or wish to discuss this matter further, please contact our customer service toll free number.