California Privacy Rights

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by Proposition 24 (the California Privacy Rights Act) in 2020 which became effective on January 1, 2023 with revised implementing regulations effective on March 29, 2023, requires that we provide California residents with a privacy policy that contains a detailed description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding your personal information. For purposes identified below, this privacy right is afforded only to California residents. If you reside in a state other than California these privacy rights do not apply to you.

Only California residents have rights under the CCPA. A California resident is a natural person (as opposed to a corporation or other business entity) who resides in California, even if you are temporarily outside of the state. You should also read June Point Lending’s General Privacy Policy located here.

June Point Lending’s collection, use, retention, and/or sharing of your personal information must be reasonably proportionate to the purpose in which your personal information is collected or processed by us. Presently the personal information we collect is relative to facilitating a mortgage loan request on your behalf. June Point Lending does not sell, share, or disclose your personal information to any affiliates or nonaffiliated third parties. June Point Lending provides your personal information only to those service providers that are providing services to accommodate your mortgage request and the personal information provided is limited to only the required information that is necessary to perform the necessary service.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include information publicly available or lawfully obtained. For purposes of this notice, this information is referred to throughout as personal information.

The California Consumer Privacy Act rights described in this notice do not apply to personal information that June Point Lending collects, processes, sells, or discloses subject to the federal privacy law (the Gramm-Leach-Bliley Act) and its implementing regulations, or the California Financial Information Privacy Act (“CFIPA”). Because June Point Lending is subject to those laws and regulations, much of the personal information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are also governed by federal privacy rights requirements. In addition, CCPA’s privacy rights likewise do not apply to certain types of personal information that are subject to the federal Fair Credit Reporting Act (“FCRA”). Some of the services June Point Lending provides is subject to the FCRA and is exempt from the CCPA requirements on that basis.

Your Rights

As a California resident, you have the following rights with respect to your personal information:

• The right to know what personal information we have collected about you, including:
  • The categories of personal information;
  • The categories of sources from which we collected personal information;
  • The business or commercial purpose for collecting, selling, or sharing personal information (as applicable);
  • The categories of third parties to whom we disclose personal information;
  • The specific pieces of personal information we collected about you;
• The right to delete personal information that we collected from you (subject to certain exceptions);
• The right to correct inaccurate personal information that we maintain about you;
• If we sell or share personal information, the right to opt out of the sale or sharing (June Point Lending does not sell or share your personal information so the ability to opt out of selling and sharing information is presently unavailable and unnecessary);
• If we use or disclose sensitive personal information for purposes other than those allowed by the CCPA and associated regulations, the right to limit our use or disclosure; and,
• The right not to receive discriminatory treatment by June Point Lending for exercising your privacy rights which the CCPA confers.

June Point Lending Prohibitions

June Point Lending cannot discriminate against you, and is prohibited from the following if you exercise your rights under the CCPA:

• Denying you a good or service;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits, or impose a penalty;
• Providing a different level or quality of goods or services to you; or,
• Suggesting that you receive a different price or rate, or from providing a different level or quality of goods or services to you, if the difference is reasonably related to the value provided to us via your data.

Conversely, June Point Lending is not prohibited from charging you a different price or rate, or from providing you a different level or quality of goods or services if a difference is reasonably related to the value provided to us by your data.

Notice At or Prior to Collecting Your Personal Information

Presently June Point Lending in the twelve (12) months prior to the last date this privacy notice was updated, has collected, and will continue to collect (as applicable) the categories of personal information described below.

Categories of Personal Information Collected

• Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number);
• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym, or user alias; other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device);
• Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) – signature, physical characteristics or description, telephone number, bank account number, credit card number, debit card number, or any other financial information (such as bank statements and information about your income and financial obligations), medical information (such as medical debts and disability income), as well as the categories listed under the Identifiers category above);
• Characteristics of protected classifications under California or federal law regarding race, color, sex/gender, age (40 and older), national origin, disability, citizenship status, marital status, military or veteran status, status as a victim of domestic violence, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave);
• Commercial information (records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies);
• Biometric information (voice recordings, from which an identifier template, such as a voiceprint, can be extracted, keystroke patterns or rhythms);
• Internet or other electronic network activity information (browsing history; search history; and information regarding your interaction with our website, application, or advertisement);
• Geolocation data;
• Audio, electronic, visual, or similar information;
• Professional or employment-related information (including employment history);
• Education information;
• Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and,
• Sensitive Personal Information (Personal Information that reveals a consumer’s Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation (1,850 ft.); racial or ethnic origin; the processing of biometric information for the purpose of uniquely identifying a consumer).

Sources Providing Personal Information

June Point Lending collects personal information directly from California residents, third party mortgage originators, and from internet service providers, credit reporting agencies, data analytics providers, government entities, operating systems and platforms, and social networks. We do not collect all of the categories of personal information indicated above from each source, and only to extent the information is necessary to provide a mortgage loan to you.

Business Purpose for Collecting Personal Information

June Point Lending currently collects and have collected the above categories of personal information for the following business or commercial purposes:

• Helping to ensure system security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors that impair existing intended functionality;
• Performing services, including maintaining or servicing accounts, providing customer service, processing/underwriting and closing a loan, or fulfilling orders and transactions, verifying your information, processing payments, providing mortgage financing, providing analytic services, or providing similar services;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance our service; and,
• Advancing our commercial or economic interests, such as by enabling or effecting, directly or indirectly, a commercial or business purpose transaction.

Categories of Third Parties For Disclosure of Personal Information

The following are the categories of personal information that we disclosed for a business purpose in the twelve (12) months preceding the last date in which this policy was updated and, for each category, the categories of recipients to whom we disclosed personal information:

• Personal Identifiers – Name, Alias, Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number).
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.
• Unique Personal Identifiers – device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym, or user alias; other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.
• Personal information described in California’s Customer Records Law – signature, physical characteristics or description, telephone number, bank account number, credit card number, debit card number, or any other financial information (such as bank statements and information about your income and financial obligations), medical information (such as medical debts and disability income), as well as the categories listed in the “Identifiers” category above.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.
• Characteristics of protected classifications under California or federal law – race, color, sex/gender (including pregnancy, childbirth, and/or related medical conditions), age (40 and older), national origin, disability, citizenship status, marital status, military or veteran status, status as a victim of domestic violence, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.
• Commercial Information – records of personal property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.
• Biometric Information – voice recordings, from which an identifier template, such as a voiceprint, can be extracted, keystroke patterns or rhythms.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.
• Internet or other Electronic Network Activity – browsing history; search history; and information regarding consumer’s interaction with website, application, or advertisement.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
• Geolocation Data.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
• Audio, Electronic, Visual, or Similar information.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.
• Professional or Employment-Related Information – including employment history; Education information.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.
• Inferences – drawn from above information to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
• Sensitive Personal Information – personal Information that reveals your Social Security number, driver’s license number, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation (1,850 ft.); racial or ethnic origin; the processing of biometric information for the purpose of uniquely identifying a consumer.
  • Vendors, service providers, and partners such as customer support providers, email providers, internet service providers, data storage providers, payment processors, operating systems, and other software providers.
  • Government entities, courts, and other legal authorities; attorneys, accountants, and auditors; ratings agencies; and credit bureaus.
  • Government-sponsored and other relevant parties to loan transactions, such as Fannie Mae, Freddie Mac, and Ginnie Mae.
  • Any future financial institution in which your mortgage loan may be brokered, a future investor that may purchase your loan, or any loan servicing organization related to the purchase or servicing of your mortgage loan.

Business Purpose for Disclosing Personal Information

June Point Lending disclosed personal information for the following business or commercial purposes:

• Helping to ensure security and integrity of retaining and using personal information;
• Debugging to identify and repair any errors in technology or processes, as necessary;
• Performing services the necessary services to provide you a mortgage loan, including any third party service providers with a need to know limited personal information to provide the necessary service; and,
• Advancing our commercial or economic interests.

June Point Lending has not sold or shared Personal Information in the twelve (12) months preceding the last revision date of this Privacy Policy. June Point Lending does not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age. June Point Lending does not use sensitive personal information for purposes other than those allowed by the CCPA and its accompanying regulations.

Retention of Your Personal Information

June Point Lending retains your personal information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. In addition, June Point Lending retains the personal information necessary to facilitate a mortgage loan according to each states record retention requirements.

Knowledge, Deletion, or Reporting an Error of Your Personal Information

You have a right to request that June Point Lending identify for you the personal information we have retained, to delete certain personal information, or to notify us of an error in your personal information.

The personal information that June Point Lending must retain regardless of a request for deletion is identified below.

Any request to June Point Lending by you to delete personal information, also applies to any service providers in which June Point Lending has disclosed information to obtain/perform the service needed to provide a mortgage loan. This is also subject in the same way to the limits below regarding when June Point Lending must continue to retain your personal information.

June Point Lending cannot delete personal information relative to:

• completing the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of June Point Lending’s ongoing business relationship with you, or otherwise perform a contract between the two of us;
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• debug to identify and repair errors that impair existing intended functionality;
• exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• comply with the state Electronic Communications Privacy Act;
• 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 June Point Lending’s deletion of the information is likely to render impossible or seriously impair the achievement of the research, if you have provided informed consent;
• enable solely internal uses that are reasonably aligned with your expectations based on your processes with June Point Lending;
• comply with a legal obligation; or,
• otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Submitting a Request to Know, Delete or Correct Your Personal Information

You may submit a request to June Point Lending to know what personal information we have, delete your personal information, or to correct any errors in your personal information by one of the following methods:

By Mail (please send a written request to):

June Point Lending Inc. ATTN: CA Privacy Rights Request 776A 6th Avenue, 2nd Floor Office 210 New York, NY 10001

Or via Email to: info@junepointlending.com

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods above. After submitting the request, and if the request is not subject to an exemption or exception as indicated above, we may require additional information to verify your authority to act on behalf of the California resident.

June Point Lending’s Process for Verifying a Request to Know, Delete, and/or Correct Your Personal Information

If June Point Lending determines that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the personal information, we may ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the personal information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Your request for identification of your personal information, the deletion of personal information (as allowed), or identifying personal information that needs correction will be processed promptly upon receipt but in no event will be processed longer than 30 business days after receipt, unless additional documentation or information must be requested to identify the potential error or to verify your identity or authorization for a third person/entity making the request.

Your Right to Opt Out of the Selling or Sharing of Your Personal Information

Since June Point Lending does not sell or share your personal information except to the extent necessary to provide you a requested product or service, there is no necessity for you to opt out of our information sharing.