Terms Of Use

As a valued customer, we prioritize the confidentiality and security of the information we collect about you. At Lower, LLC ("Lower" or "Company"), we have implemented a comprehensive policy to safeguard your personal data. This policy applies to all aspects of our organization, including our employees and any other trade names associated with Lower.

Our Privacy Pledge

• We do not sell or rent customer information. Period.
• We share customer information with certain employees and with companies providing services on our behalf to service your needs.
• We may share your personal information with non-affiliates to assist in your application and mortgage process.
• We may share information for marketing and/or joint marketing purposes.
• Our policy requires all employees and companies providing services on our behalf to keep customer information safe and to comply with our company’s customer information security expectations.
• Our privacy policy applies to potential customers as well as current and former customers.
• You may have other privacy protections under applicable state laws. To the extent the state laws apply, we will comply with them when we share information about you, and in some cases may be limited by you in what we can share.

Safeguarding Personal Information

We have adopted policies and procedures designed to protect your personal information from unauthorized use or disclosure.

We have implemented physical, electronic, and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorized access.

Our policy is to permit employees to access your personal information only if they have a business purpose for using such information, such as administering, providing, or developing our products or services.

Our policy, which governs the conduct of all our employees, requires employees to safeguard personal information about the consumers and customers we serve or have served in the past.

Information We Collect About You

At Lower, we gather information to better serve your financial needs, provide quality products and services, and meet legal and regulatory requirements. We treat all information in our possession as personal, even if you are no longer a customer.

This data may include:

• Identifying information, such as your name, age, address, phone number, and social security number.
• Employment information.
• Financial information such as your income, assets, and liabilities, as well as information about your savings, investments, insurance, and business.

Typically, we collect this information through various channels including applications and other forms you complete, conversations with our loan professionals and representatives, and in some cases, over our website.

We may also collect information from a wide range of other sources to process and/or underwrite your loan. These sources may include employers, attorneys, banks, lenders, title insurers, insurance companies, credit reporting agencies, our Company’s mobile services, and online web applications.

Sharing Information with Entities That Provide Services to, or Regulate, Our Company

As part of our everyday business operations, financial companies often share customers’ personal information with third-party entities. Additionally, we may disclose transactional details to state and federal regulators.

We share your personal information to:

• Respond to court orders and legal investigations
• Maintain your existing account or application
• Process your transaction
• Report to the credit bureaus
• Service and/or sell your mortgage loan
• Respond to our Company’s prudential state and federal regulator’s routine requests

Third parties may include, among others, title companies, appraisers, insurance companies, underwriting services, processing services, loan servicers, printing companies, software providers, data regulators, marketing services, and purchasers of loans.

Lower adheres to all applicable state laws with respect to the sharing of information.

Sharing Information with Affiliates

Lower may disclose your personal information to affiliated service providers to support our day-to-day business operations. Additionally, we share personal data with our affiliates for marketing or joint marketing efforts.

When sharing personal information, we may include:

• Your Name
• Subject Property Information
• Transactional Details (for example, Estimated Closing Date, Loan Status, Loan Amount)
• Contact Information

Our affiliates and third-party service providers are bound by confidentiality agreements prohibiting them from using any personal information for purposes other than those specified or as required by law.

For further details on limiting our sharing, please refer to the section titled “To Limit Our Sharing.”

Sharing Information with Non-Affiliates

Lower may share your personal information to non-affiliated financial service providers to support our day-to-day business operations.

Your personal information shared may include:

• Your Name
• Subject Property Information
• Transactional Details (for example, Estimated Closing Date, Loan Status, Loan Amount)
• Contact Information

However, Lower is prohibited from directly or indirectly disclosing your account number to any non-affiliated third party for marketing purposes.

We may share your data only if:

• You were provided a privacy notice
• You had the opportunity to opt-out
• You were allotted a reasonable opportunity to opt-out
• You elected not to opt-out

Lower's Internal Marketing and Joint Marketing Agreements

At Lower, we aim to keep you informed about our new and existing products. We engage in direct marketing through various channels, including mailers and email.

We also collaborate with other financial institutions under joint marketing agreements to offer additional services that enhance value.

If you wish to limit our internal or joint marketing efforts, please call (833) 920-2273.

Mobile Numbers

When you provide your mobile number for SMS texting programs, we do not share it with non-affiliated financial service providers and do not use it solely for third-party lead generation.

Cookies

At Lower, we may employ cookies on our websites and collaborate with third-party vendors who also use cookies.

If you wish to prevent information from being stored without your consent, you can adjust your cookie settings on your device.

To Limit Our Sharing

To limit sharing of your information (or opt-out), as allowed by law, contact us:

• Phone: (833) 920-2273
• Email: optout@lower.com
• Website: lower.com/privacy-policy

We may begin sharing your information 30 days after notice unless you authorize earlier. Your request remains effective until revoked.

Your Rights Under Federal Law

Federal law gives you the right to limit only the following:

• Sharing for affiliates’ everyday business purposes related to your creditworthiness
• Affiliates’ marketing use of your data
• Non-affiliates’ marketing to you

Your Data Rights

You have the right to:

• Access: Request the specific data we hold about you.
• Deletion: Request deletion of your data (except where retention is required by law).
• Awareness: Be informed when data is obtained from third parties.

To exercise these rights, call (833) 920-2273.

Changes To Our Privacy Policy

Our Privacy Policy is reviewed regularly to ensure legal compliance. If significant changes occur, we’ll notify you promptly through our website or by providing a physical copy upon request.

Definitions

Affiliates: Companies related by common ownership or control (financial or non-financial).
Non-Affiliates: Companies not related by ownership or control.
Joint Marketing: A formal agreement between non-affiliated financial companies that market products or services together.
Opt-Out: Your instruction for the company not to share certain personal data.
Cookies: Text files that identify and track a website user's visits and activity.

Other Information

California Residents

We will not share your information with companies outside of our organization except for everyday business purposes, marketing our products, or with your consent.

Vermont Residents

Vermont law requires opt-in consent before sharing non-public personal financial information or credit data with affiliates.

Credit Reporting

We may report information about your account to credit bureaus. Late or missed payments may appear in your credit report.

Telephone Communications

All calls with our team may be monitored or recorded for quality control.

Do Not Call Policy

Lower, LLC maintains an internal Do Not Call preference list per the TCPA. Requests will be honored within 30 days and valid for 5 years.

Fair Credit Reporting Act

This notice complies with §601 et seq. of the Federal Fair Credit Reporting Act (FCRA).

When processing your loan, we may request a consumer credit report. If adverse action is taken, you will receive contact details of the reporting agency and can obtain a free copy of the report within 60 days. You also have the right to dispute inaccurate or incomplete information.