1
PRINTER FRIENDLY VERSION (PDF)
VERSIÓN EN ESPAÑOL (PDF)
CALIFORNIA CONSUMER PRIVACY ACT POLICY
LAST UPDATED: DECEMBER 1, 2023
This CALIFORNIA CONSUMER PRIVACY ACT POLICY (“Policy”) is provided by AMERIHOME
MORTGAGE COMPANY, A Western Alliance Bank Company (“AmeriHome”, “we,” “us,” or “our”)
and supplements our other privacy disclosures contained in our U.S. Consumer Privacy Notice and
U.S. Online Privacy Policy. This Policy applies solely to visitors, users, and others who reside in
the State of California (“Consumers,” “Consumer,” or “you”). We adopt this CALIFORNIA
CONSUMER PRIVACY POLICY (“Policy”) to comply with the California Consumer Privacy Act of
2018 as amended and the California Privacy Rights Act (“CPRA”) and the implementing
Regulations. Any terms defined in the CCPA have the same meaning when used in this Policy.
PURPOSE
The purpose of this Policy is to comply with California law, and provide you, the California
consumer, with a comprehensive description of our online and offline practices regarding
collection, use, and disclosure of personal information (“PI”) (as defined in the CCPA) and of your
rights regarding your personal information.
COVERAGE
The rights and protections contained in the CCPA apply to consumers which are defined as natural
persons who are California residents. The rights and protections under the CCPA do not apply to
business entities or natural persons who reside outside California, for other than transitory
purposes.
YOUR RIGHTS AND CHOICES
Subject to certain exceptions under the law, the CCPA grants you the following rights:
1. The right to know what personal information the business has collected about you, including
the categories of personal information, the categories of sources from which the personal
information is collected, the business or commercial purpose for collecting, selling, or
sharing personal information, the categories of third parties to whom the business discloses
personal information, and the specific pieces of personal information the business has
collected about you;
2. The right to delete personal information that the business has collected from you, subject to
certain exceptions;
3. The right to correct inaccurate personal information that a business maintains about you;
4. If the business sells or shares personal information, the right to opt-out of the sale or
sharing of their personal information by the business;
5. If the business uses or discloses sensitive personal information for reasons other than
those set forth in section 7027, subsection (m) of the Regulation, the right to limit the use or
disclosure of sensitive personal information by the business;
2
6. The right to request the categories of personal information that we disclosed about you for a
business purpose;
7. The right not to receive discriminatory treatment by the business for the exercise of privacy
rights conferred by the CCPA, including an employee’s, applicant’s, or independent
contractor’s right not to be retaliated against for the exercise of their CCPA rights.
Note: AmeriHome does NOT “sell” or “share” (as defined in CCPA) consumer
information. Additionally, AmeriHome does NOT use or disclose sensitive personal
information for purposes other than those specified in section 7027, subsection (m)
of the Regulation.
To access your rights, please send a Verified Request to
request through a written request addressed to: Western Alliance Bank, AHM CCPA Privacy
Inquiries – Client Service, 1 East Washington Street, Suite 1400, Phoenix, AZ 85004. If you have a
loan serviced with us, you may also submit your request through your password protected account.
For more information please see the SUBMITTING A VERIFIED REQUEST section below.
CATEGORIES OF PERSONAL INFORMATION WE COLLECT:
We collect information that identifies, relates to, describes, is reasonably capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or
household (personal information). In the preceding 12 months, AmeriHome has collected the
following categories of personal information about Consumers:
Categories of Personal
Information We Collect
Description (i.e., examples that might
fit this category under the CCPA)
Categories of 3rd Parties with Whom
Personal Information was Disclosed
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.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: Advertising Networks, Data
Analytics Providers, Client Relationship
Management Software
B. California Customer
Records (per the 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
a
ccount 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.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: Advertising Networks, Data
Analytics Providers, Client Relationship
Management Software
3
C. Characteristics of
protected classifications
under California or federal
law.
Race, color, religion, sex/gender, marital
status, military or veteran status,
national origin (including
from language
use or possession of special driver’s
license), ancestry, age, familial status,
receipt of public assistance, and
exercising consumer rights.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: N/A
D. Commercial
information.
Records of products or services
obtained including prior loans obtained,
existing assets and outstanding
liabilities.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: Advertising Networks, Data
Analytics Providers, Client Relationship
Management Software
E. Biometric information.
Voice recordings as part of call
recordings.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: N/A
F. Internet or other
electronic network activity
information.
Browsing history, search history,
information on a consumer's interaction
with an internet
website, application, or
advertisement.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: Advertising Networks, Data
Analytics Providers, Client Relationship
Management Software
G. Geolocation data.
Physical location or movements only as
recorded as part of any electronic
signature records.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: N/A
H. Audio, electronic,
visual, thermal, olfactory,
or similar information.
Audio, electronic, or similar information,
as part of any voice
call recordings.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: N/A
I. Professional or
employment
-related
information
.
Current or past job history or
performance evaluations.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: N/A
4
J. Education information,
defined as
information
that is not publicly
available personally
identifiable information as
defined in the Family
Educational Rights and
Privacy Act (20 U.S.C.
Sec. 1232g; 34 C.F.R.
Part 99).
Educational records directly related to a
student
that are maintained by an
educational institution such as years in
school or student loans obtained.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: N/A
K. Inferences.
Derivation of information, data,
assumptions, conclusions, from facts,
evidence or another source of data
drawn from any of the information
identified above to create a profile about
a Consumer reflecting the Consumer’s
preferences,
characteristics, or
tendencies with respect to obtaining a
mortgage loan.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: Advertising Networks, Data
Analytics Providers, Client Relationship
Management Software
L. Sensitive personal
information
Social security, driver’s license, state
identification card, or passport number
,
a
ccount log-in, financial account, debit
card, or credit card number
, precise
geolocation. Racial or ethnic origin
,
c
ontents of mail, email, and text
messages.
Existing Customers: Our sharing of these
Categories of PI with 3rd parties is covered by
GLBA and FCRA exceptions
(see EXCEPTIONS to CCPA below)
Non-Customers: N/A
EXCEPTIONS TO THE CCPA
Personal information subject to the CCPA does not include:
• Publicly available information that is lawfully made available from government records; and
• De-identified or aggregated consumer information.
In addition, some of the rights granted you in the CCPA do not apply to some of the information we
have collected and disclosed in the categories listed above, if it is information:
o Regarding certain medical information governed by the Health Insurance Portability
and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical
Information Act (CMIA) or clinical trial data;
o Involving the collection, maintenance, disclosure, sale, communication, or use of
certain personal information bearing on your credit worthiness, credit standing,
credit capacity, character, general reputation, personal characteristics, or mode of
living by a consumer reporting agency, by a furnisher of information, and by a user
of a consumer report, to the extent such activity is subject to regulation under and
authorized by the Fair Credit Reporting Act (FRCA);
o Regarding certain personal information collected, processed, sold, or disclosed
pursuant to the California Financial Information Privacy Act (FIPA), the Gramm-
Leach-Bliley Act (GLBA) (see our separate US Consumer Privacy Notice) or the
Driver's Privacy Protection Act of 1994.
If you request your rights related to information that is not covered by the CCPA, we will so inform
you in our response to your Verified Request.
5
CATEGORIES OF SOURCES FROM WHICH WE RECEIVE PERSONAL INFORMATION
We obtain the categories of personal information listed above about consumers from the following
categories of sources:
• From you or your agent
• Advertising Networks
• Lead Generator Services
• Internet Service Providers
• Client Relationship Management Software
• Data Analytics Providers
• Government Entities
• Operating Systems and Platforms
• Social Networks
• Consumer Reporting Agencies or Consumer Data Resellers
• From other 3
rd
party service providers with which we contract.
OUR BUSINESS OR COMMERCIAL PURPOSES FOR COLLECTING PERSONAL
INFORMATION
We or our service providers use your personal information for our operational purposes, or other
notified purposes, which uses we strive to ensure are reasonably necessary and proportionate to
achieve our operational purposes for which we collect your information in the first place, or for
which we process your information, or for another operational purpose that is compatible with the
context in which we collect your personal information. For example, the following are business
purposes for which we collect or share your information:
• Performing services on behalf of AmeriHome or a Service Provider, including maintaining or
servicing accounts, providing or fulfilling orders and transactions, verifying customer
information, processing payments, providing financing, providing advertising, or marketing
services, providing analytic services, providing support and responding to your inquiries, or
providing similar services on behalf of AmeriHome or a Service Provider;
• Auditing related to a current interaction with a Consumer and concurrent transactions
including, but not limited to, counting ad impressions to unique visitors, verifying positioning
and quality of ad impressions, auditing compliance with this specification and other
standards;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal
activity, and prosecuting those responsible;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term or transient use, provided that the personal information is not disclosed to
another third-party and is not used to build a profile about a Consumer or otherwise alter an
individual Consumer’s experience outside the current interaction, including, but not limited
to, the contextual customization of ads shown as part of the same interaction;
• Undertaking internal research for technological development and demonstration;
6
• Carrying out of our obligations and enforcement of our rights arising from any contracts
entered into between you and us;
• Responding to law enforcement requests and as required by applicable law, court order, or
governmental regulations;
• Evaluation or conducting of 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;
• Any other purpose described to you during collection of your personal information or as
otherwise set forth in the CCPA/CPRA; and
• Undertaking activities to verify or maintain the quality or safety of a service or device that is
owned, manufactured, manufactured for, or controlled by AmeriHome, and to improve,
upgrade, or enhance the service or device that is owned, manufactured, manufactured for,
or controlled by AmeriHome.
CATEGORIES OF THIRD PARTIES WITH WHOM WE DISCLOSE PERSONAL INFORMATION
In order to fulfill our business and commercial purposes, including to fulfill the transaction, service
your account, or market our products and services to you, we share personal information with the
following categories of third parties with whom we contract:
• Advertising Networks
• Operating Systems and Platforms
• Internet Service Providers
• Law, Consulting or other Professional Practice Firms
• Data Analytics Providers
• Consumer Reporting Agencies or Consumer Data Resellers
• Government Entities
• To other 3
rd
party service providers with which we contract
RIGHT TO ACCESS AND REQUEST DELETION OF YOUR PERSONAL INFORMATION
The CCPA provides Consumers the right to request, pursuant to a “Verified Request,” that
AmeriHome provide access to and/or delete any personal information about the Consumer which
AmeriHome collected from the Consumer, subject to certain exceptions.
This right to request deletion is not absolute and is subject to several restrictions and
exemptions. AmeriHome reserves all rights granted pursuant to the CCPA’s exemptions
and restrictions relating to the deletion of personal information.
In the event that we receive a “Verified Request” to delete information that is not covered by a
restriction or exemption, we will notify you within 45 days and delete your personal information from
our records and direct any Service Providers to delete your personal information from its records.
In the event that we receive a “Verified Request” to delete information that is covered by a
restriction or exemption, we will deny your request and within 45 days provide you a response
indicating why it is denied.
SUBMITTING A VERIFIED REQUEST
7
A Verified Request is a request submitted by a Consumer, or a person registered with the
Secretary of State and authorized by the Consumer to act on the Consumer’s behalf (Authorized
Agent), to exercise rights under the CCPA for which AmeriHome is able to verify that the identity of
the Consumer making the request, or on whose behalf the request is made, is the Consumer about
whom we have collected the personal information.
us toll-free at 844-600-1783, or through a written request addressed to: Western Alliance Bank,
AHM CCPA Privacy Inquiries – Client Service, 1 East Washington Street, Suite 1400, Phoenix, AZ
85004. We will only consider a request to be a “Verified Request” if we can identify you by
comparing personal information you provide with personal information contained in our records
including name, property address and last four digits of social security number. If you have a loan
serviced with us, you may also submit your request through your password protected account. If
you do not have an account with us but believe we may still have your personal information, we
may require additional methods of verification, including a statement signed under penalty of
perjury. We will not use any additional information you provide pursuant to a Verified Request for
any purpose other than confirming your identify to fulfil the Verified Request.
You may only make a request for personal information from us twice in a 12-month period. We will
respond within 45 days of receiving the request. The time period to provide the required
information may be extended once by an additional 45 days when reasonably necessary with
notice to you of the extension within the first 45-day period. The disclosure required pursuant to a
“Verified Request” shall only cover the 12-month period preceding our receipt of the “Verified
Request” and shall be made in writing and delivered to you either by mail or electronically at your
option. We are not obligated to provide information to you or your Authorized Agent if we cannot
verify your identity, or if we cannot verify that the person making a request on your behalf is
authorized by you to do so.
AUTHORIZED AGENTS
You may use an agent that you have authorized to act on your behalf to make a CCPA request on
your behalf. However, we will require you, as the consumer on behalf of whom such request is
made, to verify your own identity directly with us and to provide proof that the agent has been
authorized to submit the request on your behalf. Alternatively, you or the authorized agent can
provide proof that the agent has a power of attorney pursuant to Probate Code sections 4121 to
4130.
WHERE RIGHT TO DELETE DOES NOT APPLY
We may deny your deletion request if we cannot verify your identity, we cannot verify the
authorization of your agent, if the information was not collected from you or is otherwise not subject
to the rights granted by the CCPA (see EXCEPTIONS TO THE CCPA above), or, if retaining the
information is necessary for us or our Service Providers to:
1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity,
or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
8
4. Exercise free speech, ensure the right of another consumer to exercise their free speech
rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §
1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based
on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context
in which you provided it.
Additionally, we will utilize the aforementioned criteria to determine the appropriate retention period
for each category of personal information.
SALE/SHARING OF PERSONAL INFORMATION
AmeriHome does not “sell” or “share” (as defined in CCPA) consumer information nor have
we sold your personal information in the preceding 12 months outside of the permitted sharing,
disclosures, or transfers made pursuant to the exemptions of the Gramm-Leach-Bliley Act or the
Fair Credit Reporting Act.
PERSONAL INFORMATION ABOUT MINORS
We do not knowingly collect or disclose the personal information of minors under the age
of 16 without affirmative authorization. Nor does AmeriHome have knowledge that we sell or
share the personal information of minors less than the age of 16. Our amerihome.com
websites are intended only for those persons with legal capacity to contract for a loan. We do not
knowingly collect personally identifiable data from persons less than the age of 16, and we strive to
comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a
parent or legal guardian and think your child less than 16 has provided us with information, please
contact us at [email protected]. You can also write to us at the address listed at the end of
this website Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can
learn more about how to protect children's privacy on-line at
https://consumer.ftc.gov/articles/protecting-your-childs-privacy-online to view the FTC's guide to
protecting your child's privacy online.
YOUR RIGHT NOT TO BE DISCRIMINATED AGAINST
The CCPA prohibits AmeriHome from discriminating against a Consumer because the Consumer
exercised any of the Consumer’s rights under the CCPA including, but not limited to:
A. Denying goods or services to the Consumer;
B. Charging different prices or rates for goods or services, including through the use of
discounts or other benefits or imposing penalties;
C. Providing different level or quality of goods or services to the Consumer;
9
D. Suggesting that the Consumer will receive a different price or rate for goods or services or
different level of goods or services.
However, AmeriHome shall be permitted to charge you a different price or rate, or provide a
different level or quality of good or service to you, if that difference is reasonably related to the
value provided to us by your data, should you elect to participate in any financial incentive program
as we may offer from time to time, and only after we clearly describe the material terms of the
financial incentive program. We will not use financial incentive programs that are unjust,
unreasonable, coercive, or usurious.
CHANGES TO OUR CALIFORNIA CONSUMER PRIVACY POLICY
We reserve the right to amend this Policy at our discretion and at any time. When we make
changes to this Policy, we will notify you by email or through a notice on our website homepage.
CONTACT US
If you have any questions, comments, or concerns regarding our California Consumer Privacy
Policy and/or practices with respect to personal information, please send an email to
request through a written request addressed to: Western Alliance Bank, AHM CCPA Privacy
Inquiries – Client Service, 1 East Washington Street, Suite 1400, Phoenix, AZ 85004
