Effective Date: December 1, 2018
Virginia Housing Development Authority ("VHDA", "we", "us", or "our") is committed to respecting your privacy. We have developed this Privacy Statement (this "Statement") to describe how we may collect information about you through your online interactions with us and use of our website www.vhda.com, as well as other VHDA websites, if any, which refer you to this Statement (the "Website"), how we use information, and how and under what circumstances we share that information.
When you affirmatively submit information to us or through the Website ("Users") or by other means, you consent to the collection and processing of your information as described in this Statement. We also collect certain types of Visitor Data (as defined below) from you if you visit our Website but do not affirmatively submit information to us through the Website ("Visitors"). IF YOU DO NOT AGREE WITH THE USES OF INFORMATION DESCRIBED IN THIS STATEMENT, PLEASE DO NOT USE THE WEBSITE OR SUBMIT INFORMATION TO US.
We may change this Statement. The "Effective Date" legend at the top of the page indicates when this Statement was last revised. Any changes will become effective when we post the revised Statement on the Website. Your use of the Website or submission of Personal Information following these changes means that you accept the terms of the revised Statement.
Information We Collect
The Website originates in the Commonwealth of Virginia ("Virginia"), in the United States of America ("U.S."), and is only intended for Visitors and Users who are located in the U.S. VHDA supports the expansion of housing opportunities in Virginia by providing financing and support for homeownership in Virginia, the development of rental housing in Virginia, the administration of housing related programs funded or sponsored by Virginia or the U.S., and other housing related initiatives for Virginia. VHDA does not envisage offering any services of any kind to persons located outside of Virginia. VHDA collects or processes data of persons who access the Website by collecting information about their activities when they visit the Website, when they give us information through the Website, and when they give us information by direct communications with us outside of the Website. When a person has a current business relationship or pending transaction with us, we collect information about them by the means described above and by direct communications with them and indirect communications through originating lenders. Some tenants in rental housing developments financed with VHDA loans funded, in whole or in part, with proceeds of tax-exempt bonds and/or awarded federal low income housing tax credits will have some of their Personal Information given to VHDA by the management of their rental housing development to satisfy mandatory compliance with the Internal Revenue Code. Some recipients of federal housing choice vouchers will have some of their Personal Information given to VHDA by the applicable agent. All of the information pertaining to persons who have current business relationships or pending transactions with us is subject to our records retention policies which dictate when it is deleted or destroyed. All of the information given to VHDA in connection to IRS requirements is subject to our records retention policies which when it is deleted or destroyed.
We collect information that personally identifies individual Users (as further defined below, "Personal Information") directly from you when you voluntarily request information from us, supply information through the Website (including any and all materials submitted by you when you fill out a form), interact with the Website, apply for a loan, or respond to a questionnaire or inquiry.
"Personal Information" means name, email address, phone number, mailing address, gender, age, race, ethnicity, credit score, asset information, tax returns, place of employment, income, social security number, prior homeownership, credit history, family size, and other information about persons in your household, and all other information routinely collected on residential mortgage loan applications. We collect more of the above categories of Personal Information (e.g. tax returns) regarding persons who are applying for or have been given a mortgage loan and/or a mortgage credit certificate, and persons who are or will be on the title to the applicable property with such persons (collectively, "Homebuyers"), than we do in other situations. The Personal Information we collect regarding Homebuyers, is referred to in this Statement as "Mortgage Information." All Mortgage Information is Personal Information.
We and/or Service Providers may also collect information from Users and Visitors that does not, on its own, identify a specific individual. If we link this information with the Personal Information of Users in a way that renders it individually identifiable, we will treat it as Personal Information in accordance with the terms of this Privacy Statement.
"Visitor Data" means information about you and/or your device, other than Personal Information, which includes, IP address, regional location, service provider, device types, operating system used, browser type, Cookie information, clickstream data, information about the websites you visit and the date/time of such access, how you interact with the Website, user agent string, click data, referring URL, etc. Visitor Data may be used by Service Providers for purposes outlined elsewhere herein. For more information about Cookies and other tracking technologies, please see "Cookies and Other Tracking Technologies We Use to Collect Information" below.
Please note that we may also obtain information from other sources and combine that with information we collect through our Website. For example, we may collect information about you from sources such as social media, our business partners, vendors, subcontractors, other advertising companies and publicly available sources.
Use of Information - Purposes
Use of Personal Information.
We may use Personal Information of Users to establish and manage business relations with you; to notify you of changes or updates to features of the Website; to provide you with the services you request; to respond to inquiries/requests and comments from you; to determine what content is most relevant to you; to send you promotional marketing communication, including but not limited to, via email and display advertisements; to send you newsletters and information about our products, services and promotions; for operational and personalization purposes to give each user a more consistent and personalized experience when interacting with us; to register you for a class at your request; to determine your eligibility for a grant or other program; for customer service, security, to detect fraud or illegal activities, and to enforce our other applicable policies; to prevent or investigate activity we think may be potentially illegal, unlawful or harmful to us or our customers; for archival and backup purposes; to better understand how you access and use the Website; for the purposes of trying to improve the Website, diagnose problems and respond to User preferences; and for business purposes such as marketing and research. We may also use Personal Information of Users to provide our services and to comply with applicable laws, including, but not limited to, collecting and maintaining records sufficient to enforce and, in the event of an audit, show compliance with the Internal Revenue Code with regard to mortgage credit certificates and loans made with proceeds of bonds exempt from federal income taxes, the various federal laws and regulations that govern the Section 8 Housing Choice Voucher program, and various federal and state grant programs. For additional information about the use Personal Information of Users regarding our mortgage lending see "Use of Mortgage Information" below.
Use of Visitor Data
We may automatically collect and use Visitor Data from Users and Visitors to determine what content is most relevant to our Users and Visitors; to send Users and Visitors promotional marketing communications, including, but not limited to, via display advertisements; for operational and personalization purposes to give each User and Visitor a more consistent and personalized experience when interacting with us; for customer service, security, to detect fraud or illegal activities, and to enforce our other applicable policies; to prevent or investigate activity we think may be potentially illegal, unlawful or harmful to us, Users or Visitors; for archival and backup purposes; to better understand how you, as a User or Visitor, access and use the Website; for the purposes of trying to improve the Website, diagnose problems and respond to your preferences; for business purposes such as marketing and research; and for analytical and/or real-time tracking purposes. As set forth above, Visitor Data may be transferred to Service Providers for reporting content delivery purposes and/or so that we may serve Visitors with targeted advertisements for our products and services only.
Please note that we may track the activities of Users and Visitors over time and across other websites in order to serve you with targeted advertisements for our products and services only.
We will not rent or sell your Personal Information or Visitor Data to other companies.
Use of Mortgage Information
We may use Mortgage Information to advertise our own products to existing borrowers. We publish a privacy disclosure specifically for borrowers and pursuant to the Gramm-Leach-Bliley Act. You can review that here. We also use Mortgage Information when we originate loans directly, or buy loans originated by other lenders, in each case as part of the loan approval process. We also use Mortgage Information when we obtain mortgage insurance on mortgage loans and for qualifying loans to be securitized or sold to agencies of the U.S. government, GSEs, and similar entities including, but not limited to, Federal National Mortgage Association, Government National Mortgage Association, Federal Housing Administration, U.S. Department of Housing and Urban Development, U.S. Department of Veterans Affairs, U.S. Department of Agriculture, and Federal Home Loan Mortgage Corporation ("Governmental Entities"). We also use Mortgage Information to service mortgage loans.
As set forth and in addition to the above, we may share the Personal Information and Visitor Data we collect from Users and Visitors, as follows or as otherwise described in this Statement, with vendors, subcontractors, agents, consultants, ad server companies and other service providers ("Service Providers") that may require access to such information to carry out work or perform services on our behalf, including, without limitation, performing quality control reviews, performing audits, displaying targeted behavioral advertising based upon your web browsing activity, sending commercial email, managing and updating customer lists, developing and delivering targeted advertising, providing analytics and site usage information, processing transactions and payments, administering our promotions and surveys; documenting when ads on various social media platforms result in visits to the Website and to particular parts of the Website, providing other marketing and promotional assistance, and providing other services related to the operation of our business. Service Providers may require Personal Information and Visitor Data to perform their functions on our behalf or to permit us to perform our functions.
With respect to Mortgage Information, we may also share with credit reporting agencies, the U.S. government and Governmental Entities (as defined above) and the Virginia Department of Housing and Community Development, all as required by law or for the benefit of the individual borrower to facilitate our providing them with a loan or other services. As noted above, we also may share Mortgage Information with Governmental Entities in the context of securitization or sale of those loans to such agencies. In addition, we share the name, address and social security number of persons who get mortgage credit certificates with the lenders who originated their loans to make it easy for them to prepare and file of the I.R.S. forms related to mortgage credit certificates.
Note that we may also share any/all information gathered on or via this Website: (i) in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process; (ii) if we believe your actions are inconsistent with our user agreements or policies, or to protect our rights, property or safety, or others’; (iii) in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; (iv) between and among us and any current or future parent, subsidiary and/or affiliated company; and (v) with your consent or at your direction.
We may also share de-identified or aggregated Personal Information, Visitor Data, and/or Mortgage Information, in each case which cannot reasonably be used to identify you ("Aggregated Data"). For example, we may share Aggregated Data with advertisers that partner with us to help them understand how well their advertisements performed, or with industry trade groups like the Mortgage Bankers Association, the National Council of State Housing Agencies, or with other governments or other parts of Virginia government.
Cookies and Other Tracking Technologies We Use to Collect Information
Please note that the Website uses Google Analytics, a service that transmits website traffic data to Google servers which to the best of our knowledge are located in the United States. To the best of our knowledge, Google Analytics does not identify individual Users or Visitors, or associate Users’ or Visitors’ IP addresses with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.
Users and Visitors who do not have a current relationship with us which requires us to maintain contact with them and whose information is not necessary for us to comply with laws and regulations, may contact our customer service at firstname.lastname@example.org to request they be dropped from future communications from us, including promotional emails and marketing communications.
We strive to maintain the accuracy of Personal Information collected. We will work with you to correct any information you submitted to us upon your request. It may not always be possible to completely remove or modify information in our databases, although we will make reasonable efforts to do so upon your request. Current borrowers may log-in to their account to correct or update their Personal Information. Others who wish to correct or update their Personal Information in our records may do so by sending an email to email@example.com.
How We Protect the Information We Collect
We implement security measures to maintain the safety of your Personal Information, including encryption of all Mortgage Information. However, the security of information transmitted through the internet can never be guaranteed. We (like all websites) cannot warrant or guarantee 100% security of any information you transmit to us through the Site. All collected Personal Information, Visitor Data and Mortgage Information is stored in the United States.
We store Personal Information and Visitor Data for as long as necessary for the purpose(s) listed above in the "Use of Information – Purposes" section. When Users no longer have a current business relationship with us, and we no longer use the Personal Information to comply with laws and regulations, we will keep all of the Personal Information we have per VHDA’s records retention policies. When we delete or destroy Personal Information or Visitor Data for any reason, including pursuant to our records retention policies, we also request Service Providers possessing Personal Information or Visitor Data regarding the same person to do the same. We and/or Service Providers may retain certain information for legitimate business purposes or as required by law.
Please note, however, that data you have shared with third-parties, that are not VHDA or Service Providers, may continue to exist on the servers and systems of those third-parties, and is subject to the privacy practices of those third-parties. See "Third-Party Links" below.
Managing "Do Not Track" Signals
"Do-Not-Track" ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity via cookies or other tracking technologies. We and many third-parties do not currently respond to Do-Not-Track browser signals or mechanisms. See the privacy policies of independent operators with respect to how they respond to DNT signals, as their policies may differ from our own.
The Website may contain links to websites or mobile applications maintained by independent operators, including social media websites, with which we have no affiliation other than that we have determined they might be helpful to our Users and Visitors. This Statement does not reflect the privacy practices of those websites, and you should carefully consult the privacy policies of those sites to learn about their practices. A link to any such third-party site does not mean that we endorse it or the quality or accuracy of information presented on it. We are not responsible for any practices employed on such third-party websites or applications, including the information and content contained on the website or application.
Additional Protections for Children
The Website is not targeted to children. We will never knowingly solicit or collect personally identifiable information from a child under the age of 13 without verifiable parental consent or unless authorized by law. If we discover that a child under the age of 13 has submitted personally identifiable information without verifiable parental consent, we will delete that information. If you are the parent or legal guardian of a child under 13 years old and you believe we have received personal information from your child, please contact us at firstname.lastname@example.org to request deletion of that information.
If you have questions or comments about this Statement or would like to review, update, correct delete any Personal Information you have provided, please contact us at email@example.com for Mortgage Information and at firstname.lastname@example.org for all other information. We may impose certain requirements to be sure you are who you say you are and have authority to request such changes. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect or misleading.
Changes to Our Privacy Statement
The Effective Date of this Statement is set forth at the top of this Statement. We may from time to time make changes to this Statement to reflect changes in legal or regulatory obligations or changes in the manner in which we collect and use Personal Information. We will notify you by posting the modified Statement, and its effective date, on this page. For this reason, you should regularly review this Statement and note the effective date. Your continued use of the Website after the Effective Date constitutes your acceptance of the amended Statement. The amended Statement supersedes all previous versions.