Privacy Notice for California Residents

Personal Information does not include:

The sections below describe the categories of Personal Information Vontive may collect, and may have collected within the preceding 12 months, together with the sources from which Vontive collects it, the business purposes for collecting it, and the parties to whom Vontive may disclose it. A summary of Vontive's retention standards follows.

Vontive may also collect Personal Information that does not fit squarely within a single category above—for example, the contents of communications you send to Vontive. Unless otherwise specified, the sources of such information, the purposes for which Vontive uses it, and the parties to whom Vontive discloses it are those described in the Sources, Business Purposes, and Disclosure sections of this notice.

Vontive collects and uses Sensitive Personal Information only for the purposes the CCPA permits, principally: performing the services you request, verifying and maintaining the quality of those services, detecting and preventing security incidents and fraud, and complying with applicable law. Vontive does not use or disclose Sensitive Personal Information for purposes to which the CCPA's right to limit use and disclosure applies, and Vontive does not collect or use Sensitive Personal Information for the purpose of inferring characteristics about a consumer.

Vontive collects Personal Information directly from you—for example, when you complete a Vontive application or become a Vontive customer. Vontive also collects Personal Information automatically from your computer, browser, or mobile device when you interact with the Vontive website, and may receive Personal Information from third parties, including public records and service providers.

Vontive collects Personal Information for the following purposes: to establish and maintain your account; to make credit decisions on your loan; to provide, maintain, and improve Vontive's services and products; to detect and prevent fraud and other security incidents; to conduct marketing, advertising, and promotional activities; and to comply with applicable state and federal law.

Vontive may disclose Personal Information to service providers and contractors supporting the customer transaction; data analytics providers; customer experience analytics providers; due diligence providers; business partners; purchasers of, and investors in, mortgage loans; cloud services providers; consumer reporting agencies; and law enforcement agencies, where required by law.

In addition to the purposes described above, Vontive may collect, use, and disclose Personal Information as required by law, regulation, or court order; to respond to governmental or law enforcement requests; to identify, contact, or bring legal action against a person who may be causing injury to, or interfering with, the rights or property of Vontive or of others; to support any actual or threatened claim, defense, or declaration in a proceeding before any court, jurisdictional or administrative authority, or arbitration or mediation panel; or in connection with disciplinary actions or investigations. Vontive may likewise disclose Personal Information to third parties in connection with the sale, assignment, merger, reorganization, or other transfer of any of its brands or companies.

Vontive does not sell Personal Information, and Vontive does not share Personal Information for purposes of cross-context behavioral advertising, as the CCPA defines those terms. Because Vontive neither sells nor shares Personal Information, no opt-out mechanism is required, and none is provided. Vontive has no actual knowledge of selling or sharing the Personal Information of consumers under 16 years of age.

Vontive's services are designed for, and directed to, adults. Vontive does not market to individuals who are not legal adults, does not knowingly do business with them, and does not knowingly collect their Personal Information. If you believe a minor has provided Personal Information to Vontive, please use the Contact Information section below so that the information may be deleted.

Vontive retains Personal Information for as long as reasonably necessary for the purposes described in this notice, or as otherwise permitted or required by law. In determining the appropriate retention period, Vontive considers:

Where Vontive uses Personal Information for more than one purpose, it retains the information until the purpose with the longest applicable period expires. For more information about Vontive's retention practices, please use the Contact Information section below.

You have the right to request that Vontive disclose the following information about its collection, use, and disclosure of your Personal Information:

A request to know generally covers the 12 months preceding the request. For Personal Information collected on or after January 1, 2022, you may request information covering a longer period; Vontive is not required to provide information beyond the 12-month window, however, where doing so would prove impossible or would involve disproportionate effort.

You have the right to request that Vontive delete Personal Information it has collected from you and retained, subject to certain exceptions—among them, Personal Information Vontive needs to complete a transaction you initiated, to detect and prevent fraud or security incidents, or to comply with a legal obligation. Where an exception applies to part of a request, Vontive will delete the Personal Information the exception does not cover and inform you of the basis for retaining the remainder.

You have the right to request that Vontive correct inaccurate Personal Information it maintains about you, taking into account the nature of the Personal Information and the purposes for which Vontive processes it.

The CCPA grants consumers the right to opt out of the sale of their Personal Information and of the sharing of their Personal Information for cross-context behavioral advertising. Because Vontive does not sell or share Personal Information, there is nothing to opt out of, and no action on your part is required.

The CCPA grants consumers the right to limit certain uses and disclosures of their Sensitive Personal Information. Because Vontive does not use or disclose Sensitive Personal Information for purposes to which that right applies, no limitation mechanism is required, and none is provided.

To exercise the rights described above, please submit a verifiable consumer request to Vontive through one of the following methods:

Only you, or an agent you authorize to act on your behalf, may submit a verifiable consumer request relating to your Personal Information. You may submit a request to know free of charge up to twice within a 12-month period. Submitting a verifiable consumer request does not require you to create an account with Vontive, and Vontive will use the Personal Information provided in a request solely to verify the requestor's identity or authority to make it.

If a request is manifestly unfounded or excessive—in particular because of its repetitive character—Vontive may charge a reasonable fee to fulfill it or may decline to act on it; in either case, Vontive will explain the basis for its decision.

Vontive cannot respond to a request, or provide Personal Information in response to one, unless Vontive can verify your identity or your authority to make the request and confirm that the Personal Information relates to you.

Password-protected accounts. If you hold a password-protected account with Vontive, Vontive may verify your identity through its existing authentication practices for that account.

Non-account holders. If you do not hold a password-protected account with Vontive, or if you cannot log in, Vontive may require you to validate two to three data points, depending on the nature of your request.

If you submit a request through an authorized agent, Vontive may require the agent to provide proof of your written permission to act on your behalf, and may require you to verify your identity directly with Vontive, except where the agent holds a power of attorney pursuant to California Probate Code sections 4121 to 4130.

Vontive will confirm receipt of a verifiable consumer request within 10 business days and will respond substantively within 45 calendar days of receipt. Where reasonably necessary, Vontive may extend that period once, by up to an additional 45 calendar days, and will notify you in writing of the extension and the reason for it. Vontive will deliver responses to requests to know in a readily useable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible.

From time to time, and as the CCPA permits, Vontive may offer financial incentives in exchange for the collection or retention of Personal Information; such incentives may result in different prices or rates for Vontive's goods and services. Any financial incentive Vontive offers will reasonably relate to the value of the Personal Information involved. Participation in a financial incentive program is voluntary, requires your prior opt-in consent, and may be revoked at any time, as described in the terms of the applicable program.

Vontive will not discriminate against you for exercising any of your rights under the CCPA. Unless the CCPA permits otherwise, Vontive will not deny you goods or services, charge you different prices or rates, provide you a different level or quality of goods or services, or suggest that you may receive different treatment, because you exercised a CCPA right.

Consumers with disabilities may request this notice in an alternative format by contacting Vontive using the information below.

Vontive may update this notice from time to time to reflect changes in its practices or in applicable law. When it does, Vontive will revise the “Last Updated” date below. Consumers are encouraged to review this notice periodically.