Privacy Policy

1. Introduction

Command Financial Group LLC, (collectively, “CFG”) values the trust our visitors and customers place in us when contacting us or utilizing our services. This Privacy Policy describes how we work to maintain that trust and protect that information.

In particular, this Privacy Policy details our collection, use and disclosure of personal and non-personal data you provide when using our online and/or mobile services and websites, and software provided by Command Financial Group LLC on or in connection with such services or websites (collectively, the “Site”).

Some key points we want to express:

We will NEVER sell your data or private information

There is absolutely no scenario in which we will ever violate your trust and sell your personal information.

We take data security very seriously!

Without publicly sharing our methods, your private data or sensitive information is extremely secure and safe while in our systems. *Regulations require that we maintain your data for in most cases, 2-3 years depending on the state. Your data is permanently, securely destroyed afterwards.

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

Identifiers

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.

Characteristics

Characteristics such as ethnicity, race, sex, age, citizenship status, marital status, number of dependents, ages of dependents, military or veteran status and/or service connected disability.

How data is used: Ethnicity, race and sex data is collected per requirements of the Home Mortgage Disclosure Act. Other data is collected to ensure that we identify the loan programs for which you might qualify as well as what documentation may be required from you to determine if you can qualify for a mortgage loan.

Financial

Financial information such as bank, other financial institution accounts, credit history, financial transaction history, income, salary, other compensation, real estate owned, judgement history, bankruptcy history and foreclosure history.

How data is used: Financial data is used by lenders to determine if you qualify for a mortgage loan.

Education

Education information such as the number of years of schooling.

How data is used: Education data may be used by lenders to determine if you qualify for a mortgage loan.

Household

Household information, such as the number of persons in a household (USDA loans only), household income (USDA loans only), and dwelling type of the subject property.

How data is used: Number of persons in a household and income of a household is required for USDA loans, as this loan program is only available in certain rural areas and qualifying for the program considers the entire household.

Dwelling type of the subject property is used as part of qualifying the loan and ensuring the property value is in line with the loan amount.

2.3 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/

2.4 Google Maps

Google Maps Terms of Service can be reviewed here: https://cloud.google.com/maps-platform/terms

3. Information Security and Storage

To maintain our strong security measures and practices, details in this section may be redacted or limited to the general public.

3.1 Platform Certifications, Audits & Assessments

ISO/IEC 27001

ISO/IEC 27001 is one of the most widely recognized and accepted independent security standards.

FISC Compliance

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 daily and/or 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. Cookie Policy

By using or accessing Command Financial Group’s websites (“Site”), you agree to CFG’s use of Cookies as outlined below.
For the purposes of this Cookie Policy, “CFG” or “we” means Command Financial Group LLC.

4.1 Introduction: What is a cookie?

This Cookie policy helps to explain the occasions when and why cookies may be sent to visitors to the Site (referred to in this policy as “we”, “us” or “our”). “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website-browsing equipment for record-keeping purposes. Cookies allow the Site to remember important information that will make your use of the site more convenient. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value.

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.

4.2 How CFG uses cookies?

We use cookies, web beacons, and other storage technologies from third-party partners such as Google and Facebook for measurement services, better targeting ads, and for marketing purposes. This takes place from the Site. These cookies, web beacons, and other storage technologies allow us to display CFG promotional material to you on other sites you visit across the Internet. CFG may also share information about your behavior on the Site with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you.

Analytical Purposes

CFG uses cookies and Google Analytics to analyze user activity in order to improve the Site. For example, we can use cookies to look at aggregate patterns like the average number of loan searches that users perform. We can use such analysis to gain insights about how to improve the functionality, services offered and user experience of the Site.

5. GDPR & CCPA

5.1 GDPR

CFG does not currently provide loan program services within any GDPR areas. All loan programs 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 used or stored. Some exceptions may apply.

5.2 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.

5.3 Notice at Collection of Personal Information

This disclosure covers the right to know what personal information is being collected.

5.4 Use of Your Personal Information

The personal information collected by Command Financial Group LLC is for the purpose of inquiring about, qualifying, applying for, or obtaining a mortgage loan. Your personal information will not be sold.