Some key points we want to express:
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
2.2 How your data is used
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.
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.
How data is used: Financial data is used by lenders to determine if you qualify for a mortgage loan.
How data is used: Education data may be used by lenders to determine if you qualify for a mortgage loan.
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
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.
4.1 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.
5. GDPR & CCPA
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.