Legal & Policies

Under California law, we will not share information we collect about you with companies outside of FlexPoint, Inc. unless the law allows. For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit sharing among our companies to the extent required by California law.

Loans made or arranged pursuant to the California Financing Law.

Loans made pursuant to a Real Estate Corporation, California Department of Real Estate 603E309 DRE 01206008.

Married persons may apply for an account in their own name.

This CCPA Privacy Notice is for California residents only and supplements the information contained in the Privacy Policy of FlexPoint, Inc. and its subsidiaries (collectively, "we," "us," or "our") and applies solely to visitors, clients, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") as amended by the California Privacy Rights Act ("CPRA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Purpose

The purpose of this notice is to inform California residents of their rights under CCPA. This notice includes detailed information about our online and offline practices regarding the collection, use, and disclosure of personal information as defined in CCPA.

Who is Covered

Under CCPA, consumers are defined as natural persons who are residents of the state of California. The rights and protections afforded in CCPA do not apply to any business entities or natural persons that reside outside of California for any reason other than transitory.

Information We Collect

Personal Information About Minors

We do not knowingly collect, disclose, sell, or share personal information of minors under the age of 16 without affirmative authorization. Our website and services are intended only for persons with legal capacity to contract for a loan. We comply with the Children's Online Privacy Protection Act ("COPPA"). If you are a parent, guardian, or authorized agent of a minor under 16 whom you believe may have provided us information, please submit a verifiable request.

How Information is Collected

Personal information is collected from: (1) directly from you, our clients, or their agents; (2) indirectly through information collected in the course of providing services; (3) directly and indirectly from activity on our website; and (4) from third parties such as credit reporting agencies, appraisers, and service providers.

Use of Personal Information

We may use personal information to: fulfill the reason for which it was provided; provide, support, and develop our website, products, and services; provide you with information or services you request; carry out obligations under contracts with you; conduct testing, research, analysis, and product development; protect rights, property, or safety; respond to law enforcement; respond to audits; detect security incidents; protect against fraud; and as described at the time of collection or as otherwise set forth in CCPA.

Sharing Personal Information

We may disclose personal information for business purposes to: our affiliates; service providers; and third parties you or your agents authorize. FlexPoint, Inc. does not "sell" or "share" consumer information as defined by CCPA.

Your Rights and Choices Under CCPA

1. Access and Data Portability — You have the right to request disclosure of the categories of personal information we collected about you, the sources and purposes for collection, the categories of third parties with whom we share it, and the specific pieces of information collected about you.
2. Deletion Request Rights — You have the right to request deletion of personal information we collected from you, subject to certain exceptions (completing transactions, detecting security incidents, complying with legal obligations, and others permitted by CCPA).
3. Correction of Personal Information — You have the right to request correction of inaccurate personal information we collected and retained, subject to exceptions.
4. Opt-Out of Sale or Sharing — FlexPoint, Inc. does not "sell" or "share" personal information as defined in CCPA.
5. Limit Use of Sensitive Personal Information — FlexPoint, Inc. does not use or disclose sensitive personal information other than as permitted by CCPA for business services.
6. Request Categories Disclosed for Business Purposes — You have the right to request categories of personal information disclosed about you for a business purpose.
7. Non-Discrimination — You have the right not to receive discriminatory treatment for exercising your CCPA rights.

Exercising Your Rights

Additional Information

You may make a verifiable consumer request for access or data portability twice within a 12-month period. We endeavor to respond within 45 days of receipt (up to 90 days with written notice of extension). We do not charge a fee unless the request is excessive, repetitive, or manifestly unfounded.

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, we will notify you by email or through a notice on our website homepage.

Under the Housing Financial Discrimination Act of 1977 it is illegal to discriminate in the provision of or in the availability of financial assistance because of the consideration of:

1. Trends, characteristics or conditions in the neighborhood or geographic area surrounding a housing accommodation, unless the financial institution can demonstrate in the particular case that such consideration is required to avoid an unsafe and unsound business practice; or
2. Race, color, religion, sex, marital status, national origin or ancestry.

It is illegal to consider the racial, ethnic, religious or national origin composition of a neighborhood or geographic area surrounding a housing accommodation or whether or not such composition is undergoing change, or is expected to undergo change, in appraising a housing accommodation or in determining whether or not, or under what terms and conditions to provide financial assistance.

These provisions govern financial assistance for the purpose of the purchase, construction, rehabilitation or refinancing of one-to-four unit family residences occupied by the owner and for the purpose of the home improvement of any one-to-four unit family residence.

If you have questions about your rights or wish to file a complaint, contact the management of this financial institution or:

If you communicate with us by telephone, we may monitor or record the call.

FlexPoint, Inc. and/or its service providers acting on its behalf may report information about your account to the major credit bureaus. Under the Fair and Accurate Credit Transactions Act of 2003, you have the right to directly dispute the accuracy or integrity of information reported to the major credit bureaus.

To protect your rights regarding any disputed account information, you must do the following:

• Any dispute must be made in writing to FlexPoint, Inc. at ATTN: Compliance, FlexPoint, Inc., 151 Kalmus Drive D 210, Costa Mesa, CA 92626, or email compliance@flexpointinc.com.
• Do not provide your dispute notice to another FlexPoint address — this may cause delays.
• Your dispute notice must sufficiently identify your account relationship (name, address, account number, etc.).
• You must specify what information is being reported and why you are disputing it.
• You must provide documentation to support your dispute (e.g., relevant credit report section, account statements, police report, affidavit of forgery).

In most cases, FlexPoint, Inc. will respond to your dispute notice in writing within 30 days of receiving it.

The safeguarding of customer personal and financial information is of the utmost importance to FlexPoint, Inc. We are dedicated to utilizing industry-standard security measures to protect our customers' data and comply with all applicable federal and state laws.

How does FlexPoint protect my personal information? We use security measures that comply with federal law, including computer safeguards and secured files and buildings.

How does FlexPoint collect my personal information? We collect when you apply for a loan, provide account information, or give us contact information. We also collect from credit bureaus and other companies.

Definitions: Affiliates — companies related by common ownership or control. FlexPoint, Inc. has no affiliates. Non-affiliates — companies not related by common ownership or control. FlexPoint, Inc. does not share with non-affiliates for marketing. Joint Marketing — FlexPoint, Inc. does not enter into joint marketing agreements.

Under the Equal Credit Opportunity Act, it is illegal to discriminate in any credit transaction:

• On the basis of race, color, national origin, religion, sex, marital status, or age;
• Because income is from public assistance; or
• Because a right has been exercised under the Consumer Credit Protection Act.

If you believe you have been discriminated against, please send a complaint to:

FlexPoint, Inc. is an Equal Housing Opportunity Lender. Under the Federal Fair Housing Act, it is illegal, on the basis of race, color, national origin, religion, sex, handicap, or familial status (having children under the age of 18), to:

• Deny a loan for the purpose of purchasing, constructing, improving, repairing, or maintaining a dwelling, or to deny any loan secured by a dwelling; or
• Discriminate in fixing the amount, interest rate, duration, application procedures, or other terms or conditions of such a loan, or in appraising property.

As prohibited by federal law, we do not engage in business practices that discriminate on the basis of race, color, religion, national origin, sex, marital status, age, public assistance income, or the exercise of any right under the Consumer Credit Protection Act.

If you believe you have been discriminated against, send a complaint to:

This notice is the FlexPoint, Inc. Do Not Call Policy under the Telephone Consumer Protection Act. We do not solicit via telephone numbers listed on the state or federal Do Not Call lists, unless allowed by law. FlexPoint, Inc. employees and service provider employees receive training on how to document and process telephone marketing choices.

Consumers who ask not to receive telephone solicitations from FlexPoint, Inc. will be placed on the FlexPoint, Inc. Do Not Call List and will not be called in any future campaigns. If you communicate with us by telephone, we may monitor or record the call.

It is the policy of FlexPoint, Inc. to make credit products available to all applicants who meet our business focus in a fair and consistent manner within the confines of safe and sound business practices. FlexPoint, Inc. does not discriminate against any credit applicant on the basis of race, color, religion, national origin, marital status, age, sex, disability, familial status, receipt of public assistance, or the exercise of any right under the Consumer Credit Protection Act, or on any other prohibited basis.

FlexPoint, Inc. also requires loan terms, rates, and fees to be consistent with the borrower's qualifications, that borrowers have the ability to repay the obligation, and that borrowers receive a tangible benefit from the loan transaction.

FlexPoint, Inc. expects the companies with whom it does business to adhere to similar non-discriminatory and fair lending policies and practices throughout the lending process, including application procedures, pricing, marketing, closing procedures, and compensation programs.

• Not all programs are available in all areas. Not all borrowers will qualify for all programs. Program restrictions apply.
• This is not an offer for extension of credit or a commitment to lend.
• Not all branches are licensed in every state; please contact your local office to determine eligibility.
• All loan programs are subject to FlexPoint, Inc. underwriting guidelines and available loan terms. Approvals may be subject to appraisals and other documentation requirements. Interest rates, loan programs, available loan terms, and other information on this website are subject to change without notice.

1. Our Pledge to You
   One of our top priorities is making sure that the information we have about you is protected and secure. We value our relationship with you and work hard to preserve your privacy and ensure that your preferences are honored. At the same time, the nature of our relationship may result in us collecting or sharing certain types of information about you. We explain how we use customer information in this privacy policy statement.
2. Information We Collect
   We collect information you give to us on applications, surveys, registration forms, etc.
3. How We Share Information
   We do not share information that we have about you with anyone except in response to subpoenas or for other legal reasons. The law permits us to share information about our current and former customers with government agencies or authorized third parties under certain circumstances, such as in response to subpoenas or to comply with certain laws.
4. How We Protect Information
   We strive to protect your data and safeguard it from those not authorized to see it.
5. Former Customers
   We do not share information about our former customers with anyone except in response to subpoenas or for other legal reasons. We do not share information about former customers with outside companies for their marketing purposes.
6. Customer Preferences
   We honor your choices for sharing data. To exercise your preferences, please contact us or mail the form below to:

Community Reinvestment Notice
The Department of Financial and Professional Regulation (Department) evaluates our performance in meeting the financial services needs of this community, including the needs of low-income to moderate-income households. The Department takes this evaluation into account when deciding on certain applications submitted by us for approval by the Department. Your involvement is encouraged. You may obtain a copy of our evaluation. You may also submit signed, written comments about our performance in meeting community financial services needs to the Department. (Source: P.A. 101-657, eff. 3-23-21.)

Illinois Community Reinvestment Act Notice
Under the Illinois Community Reinvestment Act (ILCRA), the Secretary of the Department of Financial and Professional Regulation (Secretary) evaluates our record of helping to meet the lending needs of this community consistent with safe and sound operations. The Secretary also takes this record into account when deciding on certain applications submitted by us.

You are entitled to certain information about our operations and our performance under the ILCRA, including information about our additional full-service offices, the public section of our most recent ILCRA Performance Evaluation, and public comments received relating to our performance.

At least 30 days before the beginning of each quarter, the Secretary publishes a nationwide list of covered mortgage licensees scheduled for ILCRA examination. This list is available from the Secretary at 320 West Washington Street, 3rd Floor, Springfield, IL 62786 and at 555 West Monroe Street, Suite 500, Chicago, IL 60661.

You may send written comments about our performance to FlexPoint, Inc. and the Secretary. You may also submit comments electronically through the Department's website at idfpr.illinois.gov/admin/cra.html.

Licensed by the Oregon Division of Financial Regulation of the Department of Consumer and Business Services. For consumer complaints, call us at 888-877-4894 or go to dfr.oregon.gov. The posting of this notice complies with the requirements of ORS 725.160, 725A.032, 86A.166, and 86A.309.

Oregon DFR Servicer Oversight
The Oregon Division of Financial Regulation (DFR) oversees residential mortgage loan servicers responsible for servicing residential mortgage loans in connection with real property located in Oregon. If you have questions regarding your residential mortgage loan, contact your servicer. To file a complaint about unlawful conduct by an Oregon licensee or a person required to have an Oregon license, call DFR at 888.877.4894 or visit DFR.OREGON.GOV.

If you are a resident of the state of Nevada, you may choose to be added to our internal do-not-call list by contacting us at compliance@flexpointinc.com, calling 888-365-1522, or writing to ATTN: Compliance, FlexPoint, Inc., 3100 Bristol Street, Suite 100, Costa Mesa, CA 92626.

For additional information you may contact the Nevada Office of the Attorney General at aginfo@ag.nv.gov, calling 702-486-3132, or writing to 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101.

Texas Complaint — TAC §80.200(b)

Texas Disclosure Statement
Pursuant to Texas Finance Code Chapter 158.101, a registrant shall provide to the borrower of each residential mortgage loan the following notice not later than the 30th day after the registrant commences servicing the loan:

The purpose of this Website Privacy Notice is to inform you on the practices we employ regarding the collection, processing, transferring, management, and storage of data derived from visitors to our websites. We are committed to safeguarding your privacy.

How Information is Collected
Information is collected by visitors to our websites, third parties, and service providers through the course of conducting everyday business in mortgage loan origination and servicing.

Collected Information
The type of information we collect may include: (1) personal and loan-related information provided by you related to the initiation, processing, and completion of a mortgage loan; (2) transactional information — data records for each transaction or usage instance; (3) usage information — standard technical data such as IP addresses, browser type, ISP, pages accessed, and date/time of access; and (4) technology tracking tools such as cookies and web beacons.

Our websites utilize cookies to help us understand your interaction with our websites, improve and personalize the experience, monitor use, and manage web traffic. You may choose which types of cookies to enable or reject depending on your browser settings. If you have enabled a Do Not Track signal for our websites, please contact us at compliance@flexpointinc.com.

How We Use Information
We use collected information to: provide services and customer support; analyze, personalize, and improve website experience; contact you for customer service and marketing (you may opt out at any time); aggregate data to understand usage trends; and improve and personalize marketing across online, email, mail, and telephone channels.

How We Share Information
We may share information with service providers to fulfill business needs, for website hosting, maintenance, marketing, and similar services. Non-personal information may be used in aggregate by third parties for compliance, business, and marketing purposes. We may also share information to comply with law enforcement requests, protect rights and safety, enforce agreements, or conduct significant business transactions (acquisitions, mergers, etc.).

How We Protect Your Information
We have implemented cybersecurity measures that meet current industry standards, guidance, and best practices. All website usage is governed by our Terms of Use.

Children's Information
Our websites are directed to persons of legal age to enter into a loan contract and are not intended for children under the age of 13. We comply with the Children's Online Privacy Protection Act. If you are a parent or guardian of a minor under 13 who may have provided us information, contact us at compliance@flexpointinc.com.

Third Party Links
For convenience, we may link to third-party websites. All third-party websites are governed by the respective owner's terms and privacy practices. Contact third parties directly for information about their practices.

Accessing Your Information
To access or update your information: log into your customer account online; email compliance@flexpointinc.com to receive, amend, or delete information; email info@flexpointinc.com to be added to our internal Do Not Call list; or click "unsubscribe" in any marketing email footer.

If you are a resident of the state of Vermont, we will not share information we collect on or about you with any company outside of FlexPoint, Inc. unless permitted to by law. We do not have affiliates and thus do not share information with affiliates. We may share information that is permitted by law, with your consent, in order to service accounts or to report to credit bureaus.