Additional California Privacy Disclosures
Effective Date: January 1, 2020
These Additional California Privacy Disclosures (the “Disclosures”) supplement the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).
These Disclosures describe how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
Unless otherwise expressly stated, all terms defined in these Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
Personal Information Disclosures
When we use the term “personal information” in these Disclosures, we mean 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. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
Collection, Disclosure, and Sale of Personal Information
In the last 12 months, we have not sold personal information about you, but we have collected and disclosed for a business purpose the following categories and examples of specific pieces of personal information, which reference the personal information described in the Our Collection and Use of Personal Information section of our Privacy Notice:
|Category of Personal Information||Collected||Disclosed for Business Purpose||Sold|
|Identifiers, including your name, social security number, IP address, email address, username and password for our mobile application, and, if you maintain an account through our Redwood Residential Acquisition Corporation Portal, your account password||✔||✔||No Personal Information Sold|
|California Customer Records (Cal. Civ. Code § 1798.80(e)), including your address, phone number, fax number, and, for disregarded entities, your bank account number and financial statement||✔||✔|
|Protected Classification Characteristics||X||X|
|Commercial Information, including Investment Information relating to the shares you purchase and hold||✔||✔|
|Internet/Network Information, including Log Data and Analytics Data||✔||✔|
|Geolocation Data, including your general geographic location or more precise location to the extent permitted by law||✔||✔|
|Professional/Employment Information, including your employer, company name or the name you are doing business as, your job title, and Diligence Information||✔||✔|
|Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)||X||X|
|Other Personal Information, including personal information you permit us to see when interacting with us through social media and personal information you provide us in relation to a question, request or inquiry||✔||✔|
Sources of Personal Information
As described in the Our Collection and Use of Personal Information section of the Privacy Notice, we collect personal information directly from you when you provide it to us, automatically when you visit our websites and other online services, and from service providers and other third parties.
Purposes for Collecting Personal Information
We collect personal information about you for the purposes described in the Our Collection and Use of Personal Information section of the Privacy Notice.
Recipients of Personal Information
As described in the Our Disclosure of Personal Information section of the Privacy Notice, we share personal information within Redwood Trust and with a variety of third parties for business purposes.
Your Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
The Right to Know
You have the right to request any or all of the following information relating to your personal information we have collected or disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have collected about you;
- The categories of sources of the personal information;
- The categories of personal information we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
- The business or commercial purposes for collecting or, if applicable, selling personal information about you.
The Right to Request Deletion
You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such “sales”.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
To Exercise Your Right to Know or Right to Deletion
To submit a request to exercise your right to know and/or right to deletion, please:
- Email us at firstname.lastname@example.org, or
- Call us at 1-866-221-3171.
We will need to verify your identity before processing your request. To do so, please include the following information with your request:
- The full name of the individual the personal information is about (the consumer);
- The full name of the individual making the request and their relationship to the consumer;
- The consumer’s address, including the state of residency;
- The consumer’s relationship to Redwood Trust, including the Redwood Trust entity, products and/or services relevant to the consumer;
- The right to be exercised, the associated request and the scope of personal
- information involved (e.g., all or a subset of the information); and
- The best phone number or email address for us to contact the requesting individual.
In order to verify your identity, we may also require the successful login to your account or additional information to match against the information we maintain about you in our systems.
In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or that the person making the request is authorized to act on your behalf (see “Authorized Agent” section below). If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
To Exercise Your Right to Opt Out of Personal Information “Sales”
Although we do not currently “sell” personal information, you may exercise your right to be added to our opt-out list in the event of future sales by clicking the link below to email us at email@example.com:
Please include with your request the information described in the To Exercise Your Right to Know or Right to Deletion section above. Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at firstname.lastname@example.org.
Minors Under Age 16
We do not “sell” the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at email@example.com to inform us if you, or your minor child, are under the age of 16.
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this Privacy Notice where we can verify the authorized agent’s authority to act on your behalf by:
- For requests to know or delete personal information:
- receiving a power of attorney valid under the laws of California from you or your authorized agent; or
- receiving sufficient evidence to show that you have:
- provided the authorized agent signed permission to act on your behalf;
- verified your own identity directly with us pursuant to the instructions set forth in this Privacy Notice; and
- directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
- For requests to opt-out of potential future personal information “sales”: receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.
Updates to These Disclosures
We will update these Disclosures from time to time. When we make changes to these Disclosures, we will change the “Effective Date” at the beginning of these Disclosures. If we make material changes to these Disclosures, we will notify you by prominent posting on our online services or through other appropriate communication channels. All changes shall be
effective from the date of publication unless otherwise provided in the notification.
If you have any questions or requests in connection with these Disclosures or other privacy related matters, please send an email to firstname.lastname@example.org.
Alternatively, inquiries may be addressed to:
Redwood Trust, Inc.
ATN: Office of the General Counsel
One Belvedere Place, Suite 300
Mill Valley, California 94941