Last Updated: April 12, 2021
2. Information Collected
You provide different types of information in order for CFG to provide our services to you. This information will be used for internal purposes only, subject to any request by law enforcement or a court order.
2.1 Information You Provide
– From Your Actions
We collect data when you submit or request information, subscribe to a newsletter, participate in a survey, complete a form or application, or otherwise actively send us data on our Site. This may include, but is not limited to, your user name, encrypted password, first and last name, email address, telephone number (including mobile phone number) and any other data included in a submitted form or application, including but not limited to application materials and answers to loan officer questions, or answers you give to any questionnaires sent to you. You may provide your specific location data when you provide it yourself through the application process or communications with your point-of-contact or assigned loan officer.
– Through Your Activity
In addition, as part of the standard operation of the Site, CFG may collect and analyze information from your browser or mobile device and actions taken on the Site, including, but not limited to, your searches on CFG, the services or loan types you search, click on or apply to, where those services are located, your activity time on the Site and each page, page views, clicks, taps, session activity, browser type, operating system, type of device, MAC address, IP address and the domain name from which you accessed the Site.
2.2 How Your Data is Used
Examples of what personal data is collected and how it is used include, but are not limited to:
Identifiers, such as your name, date of birth, social security number, copy of government issued identity card, mailing address, present address, previous addresses, telephone numbers and email addresses.
How data is used: This data is used to pull your credit report and a part of our processes to validate your identity and available financial options.
2.2 Google Analytics
Command Financial Group currently only utilizes “Google Analytics”, as provided by Google Inc.
Google Analytics Terms of Service can be reviewed here: https://marketingplatform.google.com/about/analytics/terms/us/
3. Information Security & Storage
To maintain our strong security measures and practices, details in this section may be limited to the general public.
3.1 Platform Certifications, Audits & Assessments
We adhere to the strictest financial and sensitive-data industry security standards to ensure client data is secure. We only utilize platforms who meet strict financial security standards. These standards include but are not limited to:
ISO/IEC 27001 is one of the most widely recognized and accepted independent security standards.
FISC (Center for Financial Industry Information Systems) is a public interest incorporated foundation tasked with conducting research related to technology, utilization, control, and threat/defense related to financial information systems.
3.2 Internal Security Policies, Monitoring & Audits
We issue secure devices to all employees and enforce 2-factor authentication standards for all user accounts. All internal systems undergo several audits on a regular basis. User accounts are actively monitored daily. Automated systems are in place to detect suspicious user activity. All email messages are encrypted, secured via authentication and scanned for compliance/objectionable content.
3.3 Data Storage
Loan Officer’s/Originator’s only have access to their active loan or client files. Once an application or loan is considered complete or no longer active, the data is secured by administrators and stored per state regulation requirements. Loan Officers and Loan Originators do not have access to any client’s sensitive data or files once archived.
4.1 Introduction: What is a cookie?
Session Cookies are temporary cookies that remain in the cookie file of your browser until you leave the Site.
Persistent Cookies remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). When we use session cookies to track the total number of visitors to our Site, this is done on an anonymous aggregate basis (as cookies do not in themselves carry any personal data). We may also employ cookies so that we remember your computer when it is used to return to the Site to help customize your CFG web experience.
CFG does not currently provide services within any GDPR areas. All services are limited to designated states within the United States of America. Any visitor submitted data via contact form(s) or any other form of contact, from these locations is not currently gathered, used or stored. Some exceptions may apply.
6. CCPA - California Residents
Command Financial Group LLC is exempt from the California Consumer Privacy Act requirements as personal information is subject to the federal Gramm Leach Bliley Act. The Gramm Leach Bliley Act covers all personal information collected for an inquiry, pre-qualification, or application for a mortgage loan. Any personal information collected from you for contact or marketing purposes is covered under the California Consumer Privacy Act.
6.1 Notice at Collection of Personal Information
This disclosure covers the right to know what personal information is being collected.
6.2 Use of Your Personal Information
The personal information collected by Command Financial Group LLC is for the purpose of inquiring about, applying for, or obtaining a mortgage loan. Your personal information will not be used for any other purpose, sold or shared to any third-party entities.
6.3 Is Your Information Sold?
No. We do not sell any personal information collected from a consumer or client(s).