LBA Ware Privacy Policy

Effective as of: November 1, 2016

Your privacy and the privacy of your information is extremely important to us. This Privacy Policy describes how L. Brewer and Associates, d/b/a LBA Ware, collects, processes, uses and stores information about you and how we protect the information. By using our websites (including our online resource center and project management platform) and our suite of products and services, you consent to the terms of our Privacy Policy and Acceptable Use Policy.

The LBA Ware websites and suite of products and services are referred to in this Privacy Policy, collectively, as our Services. LBA Ware customers should also refer to their license agreement and other customer agreements, which may state additional terms governing the use of our products and services.

I. THE INFORMATION WE COLLECT

LBA Ware collects information from website visitors and users of our Services in a variety of manners, and also obtains information from third parties, including our customers’ borrowers and service providers in the course of providing our Services to customers. This information includes:

Information You Provide for Sales and Product Demo Inquiries

When you request information through one of the contact forms on the LBA Ware website, we ask you to provide your name, email address, company name, telephone number, loan origination system (LOS), referral source, and other optional information you may provide.

Registration Information

When you register to use one of LBA Ware’s Services, we may collect certain information from you, including your name, title, email, company name, company address, telephone number, billing and invoicing contacts, and other information that we use to contact you or provide services to you.

Usage Information

Like most online services, we collect standard technical information when you use our Services, including but not limited to unique device identifies, internet protocol (IP) addresses, browser types, internet service providers (ISPs), the number and duration of page visits and the number of clicks.

Cookies and Other Technologies

We collect certain information through the use of cookies (also called HTTP cookies or browser cookies) and other tracking technologies. Cookies are small files that your web browser places on your computer. We may use cookies and other tracking technologies to better understand how you interact with our Services, to monitor usage by our users, web traffic, and to improve and personalize our Services. Most Internet browsers automatically accept cookies. You can disable your browser from accepting cookies or instruct it to prompt you before accepting cookies from the websites you visit.

We may also use web beacons, which are transparent graphic images on a webpage or within the body of one of our marketing emails, to allow us to measure visitor actions and assess the effectiveness of our Services or email marketing campaigns. For example, we use web beacons in our email marketing to track where a user clicks through a link in the email.

Borrower Information

In the course of delivering our Services, we receive information about our customers’ borrowers, which is provided by our customers. Borrower information includes but is not limited to name, address, loan details, real estate values, and telephone number.

In some instances, we collect information directly from our customers’ borrowers, such as when we provide post-close surveys. We process this information on behalf of our customers. Our customers are responsible for providing notice and obtaining appropriate consents to collect data from their borrowers and to provide it to us as their service provider.

Transactional Information

LBA Ware may also create transactional records of each of the transactions or other events occurring through our Services. This transactional information is generally collected for the purpose of calculating commissions, management, and reporting, to enable LBA Ware to provide its Services, to enable the services provided by third parties, and to enable LBA Ware to comply with various legal obligations.

Messaging Services and Other Communications

LBA Ware enables users of certain services to communicate with each other and with LBA Ware through those services using messaging services like chat or email. We collect and process this information to enable our customers to communicate and collaborate.

Information from CompenSafe Users

When you log in at the CompenSafe homepage, we collect and process your login ID and password to ascertain your identity and display the proper information to you.

II. HOW WE USE YOUR INFORMATION

We use the information we collect in a variety of ways to provide our Services and to operate our business, including the following:

To Provide our Services

  • To operate, test, maintain, enhance and provide features of our services;
  • To provide services and information that you request; and
  • To provide support to customers, users, and site visitors.

Improve, Analyze, and Personalize our Services

  • To understand and analyze usage trends and preferences;
  • To monitor and analyze the effectiveness of our Services;
  • To improve our Services and develop new products, services, features, and functionality;
  • To personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use our Services; and
  • To provide customized content and information.

To Contact You

We may use your email address or other information we collect to contact you for administrative purposes such as customer service or to send communications, including marketing or promotional communications relating to our Services. Generally, you have the ability to opt out of receiving promotional communications as described below.

To Aggregate, De-identified Data

We aggregate and de-identify data collected through our Services and use it for purposes such as creating and publishing reports about the use of our products and services, including users’ interests, usage patterns, and trends.

III. HOW WE SHARE INFORMATION

We take your privacy extremely seriously, and we never sell, trade or otherwise transfer lists or email addresses to outside parties. This does not include when you consent to us doing so, as well as in the following circumstances:

To Our Customers

Transactional information collected through our Services may be available to and shared with customer account administrators or other customer account managers, and third parties for commission and management purposes. LBA Ware customers may use certain information they collect through LBA Ware Services for marketing or promotional communications.

To Our Service Providers

We work with third party service providers to provide services, application development, hosting, maintenance, operations, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information. These service providers are not permitted to use information we share that might identify you for any purpose other than to provide services to LBA Ware or to you.

In Aggregate, De-Identified Form

We may make certain aggregated, de-identified non-personal information available to third parties for various purposes, including

  • For compliance with various reporting obligations;
  • For business or marketing purposes; or
  • To assist such parties in understanding our users’ interests, usage patterns, and trends.

Compliance with Laws and Law Enforcement and the Protection of Our Rights

We may disclose your information to a third party if,

  • We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request;
  • To enforce our agreements, policies and terms of service;
  • To protect the security or integrity of our Website or Services;
  • To protect the property, rights, and safety of LBA Ware, our users or the public from harm or illegal activities; or
  • To investigate and defend ourselves against any third-party claims or allegations.

In Significant Business Transactions

Your information, including personal information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

IV. PRIVACY POLICIES OF LINKED SITES

Our Website and Services may contain links to other sites. We are not responsible for the privacy practices or the content of such sites. If you have any questions about how these other sites use your information, please contact them directly.

V. SECURITY

LBA Ware has physical, administrative and technical measures in place to maintain the security, confidentiality and integrity of the information gathered through the LBA Ware website and Services, and to help protect against the loss, misuse and alteration of such information. While we take reasonable steps to protect your personal information against security breaches and unauthorized access, no data transmission over the Internet can be guaranteed to be totally secure and therefore we cannot guarantee or warrant the security of any information you send to us.

VI. INTERNATIONAL VISITORS

Our Services are hosted in the United States (U.S.) and are intended for use in connection with the U.S. real estate and residential banking market. If you choose to use them from regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the U.S. for storage and processing. By providing your information, you consent to any transfer and processing in accordance with this Privacy Policy.

VII. HOW TO ACCESS AND UPDATE YOUR INFORMATION

You can access and update the information that you have provided to us as follows:

  • You may contact us at contact@lbaware.com and request to amend or delete your personal information collected by us through online, email or telephone sales contacts if you have not chosen to obtain services from LBA Ware.
  • If you have a CompenSafe account, you can review and make changes to certain personal information, company information, and other data within the Employee/Branch/Company Details pages of CompenSafe. We require that you keep your contact information current and accurate.
  • You may opt-out of receiving marketing emails at any time by following the steps to “unsubscribe” described in the footer of our marketing emails. Your opt-out will become effective in 30 days or less.
  • If you are a customer and choose to terminate your relationship with LBA Ware, you may be permitted under your Software as a Service (SaaS) agreement with LBA Ware to obtain a copy of your data. Please refer to the text of your SaaS agreement with LBA Ware for further information.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may be revised from time to time. If we make material changes to our Privacy Policy, we will make reasonable efforts to notify you of the changes by sending notice to the primary email address provided to us and/or by placing a notice on our Website.