Part 573, Chapter V, Title 12 of the Code of Federal Regulation (Privacy of Consumer Financial Information) restricts the use of Consumer Financial Information and requires that certain disclosures be provided to consumers and customers.
The Fair Credit Reporting Act was implemented to assure fair, accurate and timely reporting of credit information. Among other provisions, the Fair Credit Reporting Act directs users of credit information as to the limitations of sharing information. There are other laws applicable to consumer and customer privacy, for example, the Right to Financial Privacy Act describes how and under what conditions financial institutions are obligated to provide an individual's records to government agencies, and the Bank Secrecy Act describes under what circumstances suspicious activity must be reported.
It is the policy of Colonial Savings, F.A. and its operating divisions and affiliates to respect the privacy of persons seeking information or services from us. Colonial employees are to keep customer information confidential. Colonial seeks to abide by the laws and regulations governing access to customer activity.
A. Categories of Information We Collect
We collect non-public personal information about you from the following sources:
- Information we receive from you on applications or other forms,
- Information about your transactions with us, our affiliates, or others; and
- Information we receive from a consumer reporting agency.
B. Web Site Privacy
Persons may browse our web site anonymously. Colonial Savings, F.A. tracks which pages of our site are visited and we note users' ID (host) addresses (as all web sites do automatically), but this tracking does not gather information about individuals. This tracking allows Colonial to identify current usage patterns in order for us to improve the information we provide.
Colonial Savings, F.A. has the ability to gather specific information from web site users only when web site users elect to provide information to us such as in the case of users completing and transmitting a mortgage prequalification form.
Colonial's digital ID allows the user's browser to verify Colonial's Internet identity every time a user visits our site and insures that information users choose to send us will be delivered only to Colonial. In addition, portions of Colonial's site have encryption capabilities, making information transmissions from or to consumers secure from third party interception.
C. Sharing Customer Information
We do not disclose any non-public personal information about our customers or former customers to anyone, except as permitted by law.
Conducting our Business
Colonial may provide customer information to third party companies in order for Colonial to conduct its normal business of originating and servicing loans and acceptance of deposit and transaction accounts. Information on accounts at Colonial may also routinely be reported to credit bureau agencies. Colonial may also provide customer information as provided on applications or other forms to marketing companies in order to facilitate Colonial's own marketing endeavors. Colonial and its affiliated companies, may enter into Joint Marketing Agreements with Third Party Companies to offer our customers products or services that we consider beneficial.
Complying with Applicable Law
Colonial Savings is required to comply with various laws governing consumer information. This includes, for example, an obligation to report suspicious activity involving consumer accounts. Another example includes the requirement to permit access by regulators to information in the course of routine examinations. It is the expressed policy of Colonial Savings, F.A. to abide by the laws and regulations governing its operations. Colonial will report and allow access to consumer information only within the parameters set by the laws and regulations.
Making Available Special Products and Services
Colonial Savings is affiliated, through common ownership, with DuBose and Associates (also d/b/a Colonial National Insurance Services), Colonial Life Insurance Company of Texas, Colonial Mortgage Insurance Company, CLICOT Agency, Colonial Lloyds and First Western Title Co. Colonial may share information regarding our customers' accounts with our affiliates. For example, mortgage loan applicants may be asked whether they are interested in receiving a quote on insurance. Colonial will not share credit reports or third party information with our affiliates.
Additionally, Colonial Savings administers an automated loan payment plan known as the Interest Saver Program. In order for this program to be offered to our customers, basic loan customer information may be made available to a marketing group.
D. Colonial's Customer Privacy Principles
We restrict access to non-public personal information about you to our employees who need access to the system containing your information in order to perform their job. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information. We will continue to update these safeguards as technology changes occur.
In recognition of the high level of trust and confidence our customers have in Colonial Savings, the following Customer Privacy Principles have been adopted as a guide for our officers and employees to follow in the use of customer information.
- We recognize and respect our customer's expectations of financial privacy.
- We will limit the collection and use of customer information to the minimum necessary to offer and deliver the products and services that we provide.
- We will restrict access to customer information to authorized employees.
- We will strive to maintain customer information as accurate, current and complete as possible. Colonial will be responsive to customers' requests to correct errors.
- We will establish safeguard standards for the security and confidentiality of customer information.
- We will not reveal specific information about customer accounts or other personally identifiable data to unaffiliated third parties, unless (1) the information is provided to help complete a customer initiated transaction; (2) the customer requests it; or (3) the disclosure is allowed or required by law.
- Whenever we hire other organizations to provide support services, we will require those organizations to adhere to similar privacy principles.
A copy of this policy will be maintained at each of our branch and loan production offices and will be available to the public upon request.
Customers may address questions regarding privacy issues by writing to the Mortgage Services Department, Colonial Savings, P. O. Box 2988, Fort Worth, Texas 76113 or by calling 817-877-9599 or 1-800-937-6001.