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|Rev. October 2021|
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Effective Date: 01/01/2020
- If you have a financial product or service with us for personal, family or household use with one of our businesses, that business would also have delivered to you a Privacy Notice that explains how that business collects, uses and shares information about you and offers you certain choices with respect to the use and sharing of your personal information.
- This Site is not intended for children under 13 years of age. We do not knowingly solicit information online from, or market online to, children under 13 years of age.
- Wireless service providers, Internet service providers, device manufacturers and/or social media platforms may have their own privacy notices that are different from this one for the information they may access through your use of the Sites. We encourage you to read their privacy notices as the collection, uses and sharing of information by those third parties may be different than Impac Mortgage.
- Our mobile, social media, or other online services, sites or pages may have additional terms about the privacy or use of your information. Please review the privacy notice for the specific Site you are using.
In the course of offering services or products to you or your household, we may collect or receive about you which constitutes personal information. Generally speaking, personal information is any information that can be used, directly or indirectly, to identify, locate or contact someone. Types of personal information include names, physical addresses, mailing addresses, social security numbers, email addresses, phone numbers, bank account numbers and driver’s license numbers. Under certain circumstances, personal information may also include other information that can reasonably link to a particular person, such as internet protocol (IP) addresses, unique device identification numbers, employment information, medical information and internet activity.
How We Collect Personal Information
Typically, we receive personal information directly from you when you apply for a loan or inquire about our loan products or services, or from others in the course of performing a service to support your inquiry or, or loan. For example, you may provide your personal information for us to contact you about a mortgage product, provide information about your mortgage for servicing related function, or for consultation on interest rates. We collect personal information through services authorized by you. For example, we may access personal information in the course of performing employment and income verifications when you apply for a loan.
We also collect personal information through our websites (www.impaccompanies.com, www.impaccorrespondent.com, www.impacwholesale.com, www.cashcallmortage.com). For example, if you set up an account for customer portal access on our website, we will collect information such as your name, email address, username and password, and we will receive any documents you submit through the customer portal. If you register to apply for job opportunities through our website, we will collect your name, email address, password and phone number, and will receive any application information you submit. And if you contact us through our website, we will receive your name, email address and any comments included in your message. Our web servers may also collect information from visitors such as IP address, browser type and version, time zone setting, operating system and platform. Some web browsers allow the user to send “do-not-track” signals to websites, but our website does not respond to those signals.
Our website, like most websites, employs “cookies” and similar technologies. Cookies are small files that are stored on your computer or mobile device when you visit our website and allow us to recognize your browser and obtain information about your use of our website. For more information about our cookies policy, please refer to the company’s Cookies Policy.
How We Use Personal Information
We use the personal information we collect from you to fulfill the purpose for which you provide it. For example, you may provide us with personal information in order for us to service your loan account or support your service needs. We may also use your personal information: (1) to provide you with information, products or services that you request from us; (2) to provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you; (3) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; (4) to improve our website and present its contents to you; (5) for testing, research, analysis and product development; and (6) for any other purpose with your consent.
Disclosure of Personal Information
We may disclose personal information we collect from you: (1) to our subsidiaries and affiliates; (2) to contractors, service providers, and other third parties we use to support our business; (3) to fulfill the purpose for which you provide it; (4) to a buyer or other successor in the event of a sale or transfer of some or all of our business or assets; (5) for any other purpose disclosed by us when you provide the information; (6) to comply with any court order, law or legal process, including responding to any government or regulatory request; (7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; (8) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others; or (9) with your consent. We do not sell or otherwise share personal information with third parties for direct marketing purposes.
Impac Mortgage Corp.
4000 MacArthur Blvd., Suite 6000
Newport Beach, CA 92660
Your California Privacy Rights
Effective Date: 01/01/2020
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (CFIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you or your agents. For example, from documents that you provide to us related to the services for which you engage us.
- Indirectly from our/you or your agents. For example, through information we collect from our/you in the course of providing services.
- Directly and indirectly from activity on our website (www.impaccompanies.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order complete your mortgage request, we will use that information to process your loan application.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Visiting our company’s request site
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
How to Contact Us
Impac Mortgage Corp.
Attn: Customer Care
4000 MacArthur Blvd., Suite 6000
Newport Beach, CA 92660
CCPA Data Subject Access Request (DSAR) Center
If you are a California resident interested in submitting a request to Impac under the California Consumer Privacy Act (of 2018, “CCPA”), please fill out the DSAR form here. If you have multiple requests, please note that you will have to submit a separate form for each request. Required fields are marked with an asterisk*
This Cookies Policy applies to Impac Mortgage Corp. and its subsidiaries Impac Mortgage Corp. dba Excel Mortgage & Impac Mortgage Corp. dba CashCall Mortgage (collectively, “we,” “us,” “our,” or “Impac”) linking to this Cookies Policy and forms part of the Privacy Notice, which describes our data handling practices and is available here. On the Impac Services, Impac and third parties, including our advertising- and marketing-related service providers and partners, use a variety of technologies including cookies ('Cookies'). Cookies vary depending on the services and includes but is not limited to cookies, web beacons, tags, and scripts etc.
What are Cookies?
The Impac Services automatically log certain information about visits to the Impac Services using Cookies, such as the number and frequency of visitors, technical information about browsers and devices used to access the Impac Services, and information about crashes or other technical issues. The Cookies which log this information are necessary to allow the Impac Services to function.
We and third parties may automatically collect certain information through Cookies about your activities over time across the Impac Services as well as across third-party sites, apps or other media. Cookies may be included in our web pages, mobile pages, emails, and other digital content. They may assign or collect unique cookie IDs or other identifiers associated with your browser or device. They may collect information while you are using our Impac Services or while they are running in the background of your device.
Cookies on the Impac Services may be served directly by Impac (referred to as 'first-party cookies') or by others such as advertisers and data analytics companies (referred to as 'third-party cookies').
Cookies are browser- and device-specific and may endure for different periods of time. Some are deleted automatically once you close your browser or exit the Impac Service. These are sometimes referred to as 'session cookies'. Other cookies are 'persistent cookies', meaning that they remain on your device after your browser is closed.
Your Choices, Including Opt-Outs
Most browsers accept cookies by default. You may be able to change the settings to have your browser refuse certain Cookies or notify you before accepting cookies. To do so, please follow the instructions provided by your browser which are usually located within the 'Help', 'Tools' or 'Edit' facility. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link and you should review the cookies policy of the relevant third party to find out more about their cookies.
Impac Mortgage Corp.
4000 MacArthur Blvd., Suite 6000
Newport Beach, CA 92660