PRIVACY POLICY
Effective Date: 8/1/2008
At Financial Freedom we value the trust you have placed in us, and we are committed to earning and maintaining your confidence. We understand there is certain information you do not want to share with everyone, and we share your concern about safeguarding the information you provide to us. This is why we have adopted this privacy policy (this "Policy"). This Policy is provided to you by each of the companies within the Financial Freedom family that are listed at the end of this Policy. If new companies are added, we will add them to the version of this list posted at www.imb.com/privacy. For convenience, these companies are referred to collectively as "Financial Freedom," "we," "us," "our," or "ours." The words "you," "your," or "yours" refer to each individual who is one of our customers or former customers, and other individuals who obtain or request a financial product or service from us or use our Web site currently located at www.financialfreedom.com (our "Web site"). For clarity, this Policy applies to all our customers, former customers, and other individuals who obtain or request a financial product or service from us or use our Web site or affiliated Web sites.
Information Collection
This Policy describes the categories of information we collect, how we use that information and the limited circumstances under which we share it. We collect information about you that we believe will be necessary or useful in processing or administering products or services that you have requested from us. We will also collect information in order to notify you about products, services and other opportunities we think will be of interest to you.
We automatically collect certain information on our Web site that does not reflect or reference an individually identifiable user ("Non-Personal Information") to help us understand how our users use our Web site and for other analysis. We also collect certain information from several sources that relate to you individually or that may personally identify you, such as your name, address, e-mail address, telephone number, Social Security number, certain financial information, financial transaction data, or other data which can be reasonably linked to such personal information ("Personal Information").
We may collect Non-Personal Information and Personal Information from a variety of sources, such as the following: (1) information provided by you in applications or other forms or via telephone or in person, or in connection with obtaining financial products and services such as mortgage loans, deposit accounts, and investment products and services; (2) information obtained from a consumer reporting agency; (3) information about your transactions with us, our Affiliates (defined below) or others; (4) information we automatically collect from you when you visit our Web site; and (5) information you choose to share with us when you visit our Web site.
Cookies
To provide better service and a more effective Web site, we use "cookies" as part of our interaction with your Web browsers. A "cookie" is a small text file placed on your hard drive by our Web server. Our cookies cannot retrieve any other data from your hard drive, pass on computer viruses, or capture your e-mail address. Cookies are commonly used on Web sites and do not harm your system.
We may use cookies to record Non-Personal Information about: (1) visitors' preferences; (2) user sessions on our Web site; what pages users access or visit on our Web site; and (3) past activity on our Web site in order to provide better service when visitors return; (4) alert visitors to new areas that we think might be of interest to them when they return to our Web site; (5) customize Web content based on visitors' Web browser type or other information; and (6) register to use certain online services, such as Internet banking.
Our cookies do not collect Personal Information and we do not combine information collected through cookies with Personal Information to identify who you are or your e-mail address. We may combine Personal information with cookies for other purposes, such as tracking or marketing preferences. By configuring your preferences or options in your Web browser, you determine if and how a cookie will be accepted. However, if you configure your Web browser so that "cookies" are turned off, our Web site will not be able to process your transaction. If this happens, please turn your cookies back on and log onto our Web site again.
Web Beacons
A Web beacon is a graphic image (such as a pixel tag or clear GIF) that is placed on a Web page or in an e-mail message to monitor user activity (such as whether the Web page or e-mail message is read or clicked). They are often invisible and may be very small in size. They are also used on many Web pages for alignment purposes. We sometimes use Web beacons to provide an independent accounting of how many people visit our Web site or to gather statistics about Web browser usage at our Web site. Some of our web pages and HTML-formatted e-mail newsletters use Web beacons in conjunction with cookies. It is difficult for you to limit the use of Web beacons because there is no easy way to distinguish their use from alignment and other purposes. They may be loaded from a different Web server than the rest of the page.
Information Uses
We use Personal Information and Non-Personal Information for internal purposes, such as (1) protecting your accounts from unauthorized access or identity theft; (2) servicing or processing your requests for product or service; (3) maintaining or servicing the your account (4) informing you about financial products and services that may be of interest to you; (5) enhancing your experience on our Web site; and (6) performing administration and technical support for our Web site.
Information Sharing Within Our Affiliates
There are times when we will share Non-Personal Information or Personal Information with our Affiliates that either currently exist or that we may create or acquire in the future. However, we will only do so in order to provide you with superior service, inform you of product and service opportunities that may be of interest to you, improve and develop our products and services, or perform other business functions. "Affiliates" means each of the companies within the Financial Freedom family that are listed at the end of this Policy and any other companies that we own or control. Affiliates may include any of the following categories of companies: financial services providers, such as consumer lending and mortgage banking companies, life and casualty insurance companies, insurance agencies, securities brokerage firms, trust companies, and companies that provide settlement services, such as title agencies, escrow companies, and appraisal firms; and others, such as non-profit organizations.
Information Sharing with Unaffiliated Third Parties
Unlike some other financial institutions, we do not sell customer lists or other information about our customers to unaffiliated third parties.
From time to time, we might establish a business relationship with unaffiliated third parties that we believe are trustworthy and that we have asked to confirm that their privacy practices are consistent with ours to provide us with marketing and solicitation services, such as printing, marketing fulfillment, data management, promotional services, marketing services, Web hosting, Web development, etc. We provide these companies with the information needed for them to perform these services. In addition, we may engage in joint marketing with unaffiliated financial institutions that we believe are trustworthy and that we have asked to confirm that their privacy practices are consistent with ours for various financial products and services that we may or may not offer on our own, but we think will be of interest to our customers, such as credit card, insurance, investments, etc. In such cases, "Financial Freedom" will always be identified in the joint marketing materials or solicitation. We may disclose Non-Personal Information and Personal Information to these unaffiliated third parties that perform these services on our behalf or to other financial institutions and with whom we have joint marketing agreements. Our agreements with these companies are subject to confidentiality provisions and restrictions that prohibit using the information beyond the performance of the specified services or in connection with the jointly marketed product or service. For California residents, we will not share your Financial Freedom Transaction Information with unaffiliated third parties without your express consent. However, unless you opt-out we may share other Nonpublic Information with companies with which we have joint marketing agreements.
Although unlikely, at times we may be required by law or litigation to disclose Personal Information. We may also disclose Personal Information if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary. We may also submit Non-Personal Information and Personal Information to unaffiliated third parties for fraud prevention and security purposes.
Maintenance of Accurate Information
We work hard to ensure your information is as accurate, current and complete as possible. If you ever find that our records are inaccurate or not current, please contact us at the telephone number on your account statement. If the record is within our control, we will correct any inaccurate or incomplete information.
Managing Your Personal Information and Privacy Preferences
Consistent with our goal of protecting you privacy and giving your choices regarding your information, you may restrict the sharing of Personal Information with our Affiliates and the unaffiliated third parties we do business with. You also may limit our Affiliates from marketing their products and services to you based on information that we share with them. Nothing prohibits the sharing of information necessary for us to comply with applicable law or legal process, in our determination, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.
For your convenience, you can indicate and submit your privacy choices at www.imb.com/privacyChoices
You may make your privacy choice(s) at any time. Your choice(s) will remain unless you state otherwise. But, if we do not hear from you we may share some of your information with affiliated companies and other companies with whom we have contracts to provide products and services, and our affiliates may use information that we share to market products or services to you.
Protecting Children's Privacy Online
The safety of children online is very important to us. We do not knowingly collect Personal Information from children under the age of 13 online. If we become aware that we have inadvertently received Personal Information online from a user under the age of 13, we will attempt to delete the information as soon as possible. Because we do not knowingly collect Personal Information from children under the age of 13 online, we also do not knowingly distribute such information to third parties.
Security
Access to our systems containing Non-Personal Information or Personal Information is only provided to those employees and agents whom we determine need it for the purpose of providing products or services to you. We maintain physical, electronic, and procedural safeguards that comply with allocable federal and state standards to protect your information. We use industry standard security measures to protect your information so that it is not made available to unauthorized parties, including using Secure Socket Layer (SSL) technology for encryption and transmittal of information (including your Personal Information) on or through our Web site. However, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot and do not guarantee or warrant the security of any information you transmit on or through our Web site, and you do so at your own risk.
Online Marketing
When browsing the Internet, you may see a banner ad for a Financial Freedom product or service. These ads may appear on non-Financial Freedom Web sites. We use third party advertisement serving companies to serve our ad banners to sites on which we have paid to advertise. If you click on one of our ads, you go to the Financial Freedom Web site offering that particular product or service. Any vendor who runs these ads for us has agreed to follow this Policy. Sometimes, these ads may contain Web beacons or cookies to gather anonymous user data, such as how many people clicked through a particular ad. Our Policy does not cover any use of information that a third party advertisement serving company may collect from you. The companies that distribute our ads are prohibited by contract from using information other than for the agreed upon purpose—to help us market our products and services and to measure response rates.
Links to Third Party Web Sites
We are not responsible for the information collection practices of the non-Financial Freedom links you click to from our Web site. We cannot guarantee how these third parties use cookies or whether they place on your computer cookies that may identify you personally. We urge you to review the privacy policies of each of the linked Web sites you visit—before you provide them with any information.
State Laws
You may have other rights under applicable state laws, such as those in Vermont, California and Nevada. We will comply with applicable state laws that provide you with greater privacy rights, to the extent not preempted by federal law.
For Vermont residents only, Vermont law requires that we not share Personal Information we collect about Vermont residents with nonaffiliated third parties except as permitted by Vermont law, such as with the consent of the customer, to service the customer's accounts, or to other financial institutions with which we have joint marketing agreements.
For California residents only, California law requires that we not disclose Personal Information about you to nonaffiliated third parties except as permitted by California law, such as with the consent of the customer, to service the customer's accounts, or to other financial institutions with which we have joint marketing agreements.
For Nevada residents only, Nevada law requires that we also provide you with the following contact information regarding "do-not-call" lists: (a) Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Telephone 702-486-3132; e-mail: BCPINFO@ag.state.nv.us; and (b) Financial Freedom Senior Funding Corporation, 1 Banting, Irvine, CA 92618, 1-800-500-5150.
Policy Changes
We may make changes to this Policy from time to time and will inform you of changes, as required by law. To review the most current Policy, please check this page and the link to this page from our homepage. The current Policy shall replace any previous Policies that are inconsistent.
Financial Freedom Family
The following is a list of the companies or businesses within the IndyMac Federal Bank family to which this Policy applies: IndyMac Federal Bank, FSB., Financial Freedom Senior Funding Corporation, IndyMac Financial Services, Inc., IndyMac Agency, Inc., IndyMac Securities Corporation, IndyMac Agencies Inc., IndyMac Retained Assets, IndyMac Commercial Lending Corporation, MortgageLine (a DBA of IndyMac Federal Bank), LoanWorks (a DBA of IndyMac Federal Bank), Loan Associates, LLC. IndyMac India PLC, Global Resources, LLC, Global Resources Investments, LLC, Global Resources Management, LLC.
Important Privacy Choices for Consumers
We honor our customer's privacy choices. For accounts with multiple customers we will apply an opt-out by any account holder to all account holders on the account. You have the right to control whether we share some of your personal information. You also have the right to control how that information is used. Please read the following information carefully.
Your Rights
You have the following rights to restrict the sharing of personal and financial information with our affiliates and outside companies that we do business with. You also have the right to limit our affiliates from marketing their products and services to you based on information that we share with them. Nothing prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.
Your Privacy Choices: If you have already conveyed your privacy choices, you need not submit them again. Remember, you may convey your preferences by calling our toll free number 877-210-2336 at any time, or online at www.imb.com/privacyChoices.
You may make your privacy choices(s) at any time. Your choice(s) will remain unless you state otherwise.
For information regarding your account, please check your statement for the appropriate customer service number.