Effective Date: January 1, 2020
This Privacy Notice explains how we collect, use, disclose, and otherwise process personal information in connection with our services. This Privacy Notice is not, however, a contract and does not create any legal rights or obligations.
Table of Contents
- Who Are We?
- Our Services
- Region Specific Disclosures
- What is Personal Information?
- Our Collection and Use of Personal Information
- Our Disclosure of Personal Information
- Children’s Personal Information
- Third-Party Websites
- Updates to this Privacy Notice
- Contact Us
Who Are We? Redwood Trust is a specialty finance company focused on making creditsensitive investments in single-family residential and multifamily mortgages and related assets and engaging in mortgage banking activities. Redwood Trust is headquartered in Mill Valley, California. When we use the terms “Redwood Trust”, “we”, “us”, or “our” in this Privacy Notice, we are referring to Redwood Trust, Inc. and each of its subsidiaries doing business under the Redwood Trust and RWT Horizons brands.
Redwood Trust does not include and this Privacy Notice does not cover our subsidiaries doing business under the CoreVest brand. For information about CoreVest, please visit their website at www.corevestfinance.com.
Our Services: When we use the term “services” in this Privacy Notice, we mean the services that we offer through which we process the personal information of:
- visitors to the websites that post or link to this Privacy Notice, such as www.redwoodtrust.com, www.ir.redwoodtrust.com, and www.rwthorizons.com,
- prospective and actual investors,
- representatives of businesses with whom we interact, and
- users of our mobile application.
The term “services” does not include, and this Privacy Notice does not cover:
- the personal information we process about the loans we buy or originate, because those activities are covered by a federal privacy law known as the Gramm-Leach-Bliley Act (“GLBA”) (we separately provide annual GLBA notices to individuals eligible to receive such notices, the latest copy of which is available here),
- when we act as a service provider processing personal information on behalf of another business (our contract with the business governs those activities), or
- personal information we process about our job applicants, employees and personnel (we maintain a separate notice for such “HR data”).
Region Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states or regions. Please refer below for disclosures that may be applicable to you:
- If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
What is Personal Information?
When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or reasonably linked to you.
Our Collection and Use of Personal Information
The personal information we collect, the way we collect it and how we use it depend on our relationship with you and how you interact with us.
Collection of Personal Information
We and our third-party partners and providers collect certain personal information you choose to provide us through our websites, which may include:
- Newsletters and Email Communication: Our websites allow you to sign up for our mailing list and email alerts by providing your email address in the available web form. We use your email address to communicate with you about our services and exciting developments at Redwood Trust, which may include marketing communications. You may ask us not to send you marketing communications by following any available opt-out instructions in the marketing communications you receive. Please note that we may continue to send you non-marketing communications even after you opt out.
- Contact Us: Our websites allow you to connect with us through an online web form that collects contact information (such as your name, company, title, email address, address and fax number) and a custom message from you. You may also choose to contact us at one of the designated addresses or phone numbers identified on our websites and provide us personal information in connection with your message. We use this personal information to communicate with you in connection with your request, including corresponding with you about our services, investment opportunities, and loan and security purchasing opportunities.
As is true of most digital platforms, we and our third-party partners and providers also collect certain personal information automatically when you visit or interact with our websites and other online services, which may include:
- Log Data, including your internet protocol (IP) address, operating system, browser type, browser id, the URL you entered and the referring page/campaign, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our services.
- Analytics Data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and objects you view, click or otherwise interact with (also known as “Clickstream Data”).
- Location Data, including your general geographic location based on the Log Data we collect or more precise location to the extent permitted by law.
Cookies and Other Related Technologies
Please note that some third-party partners and providers may also directly collect personal information about your online activities over time and across different websites after visiting our websites and other online services. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our websites and other online services, as some features and offerings may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use.
Use of Personal Information
We use the personal information we collect from our website visitors to:
- Administer and improve our websites and other online services;
- Test different configurations of our websites and other online services;
- Diagnose errors and problems with our websites and other online services;
- Conduct research and analytics on visitor usage and activity trends relating to our websites and other online services;
- Remember you and the choices you have made in relation to our services;
- Identify how you use our websites and other online services to facilitate our web traffic analysis;
- Provide you with news about Redwood Trust and the services we offer, including marketing communications tailored to you;
- Respond to your comments and questions and provide you support.
Collection of Personal Information
When you explore investing in or become an investor of Redwood Trust, we collect personal information directly from you or indirectly from brokerage firms that represent you, which may include:
- Contact Information, such as your name and address;
- Account Information, such as your username and password for our mobile application;
- Investment Information, such as your social security number, bank account number, share purchasing history, number of shares held, the value of the shares and the dividends you receive.
Use of Personal Information
We use the information we collect from our prospective and actual investors to:
- Provide you with information about our company, your investment and any other investment opportunities at Redwood Trust;
- Facilitate the investment transaction and the payment of dividends;
- Prepare tax returns and other investor-related documents;
- Manage and analyze our cap table.
Representatives of Businesses
Collection of Personal Information
When you interact with us on behalf of a mortgage originator, investment broker or another business we engage or interact with, we collect certain personal information from you and the business you represent, which may include:
- Contact Information, such as your name, address, email address, and phone number;
- Account Information, such as your username and password for our mobile application, and, if you maintain an account through our Redwood Residential Acquisition Corporation Portal, your account password;
- Professional/Employment Information, such as your employer, company name or the name you are doing business as, your job title, and, for certain disregarded entities, we may also collect your social security number, bank account number and financial statements when the entity does not maintain its own;
- Diligence Information, such as work history, educational history, references or other information that you may provide on a resume, statement of work, agreement or similar document in connection with the negotiation, evaluation and/or fulfillment of our engagement with the business you represent.
Use of Personal Information
We use the personal information we collect from business representatives to:
- Facilitate and maintain the relationship between us and the business you represent;
- Conduct due diligence and risk management relating to our engagement with the business you represent;
- Process payments for loans, goods or services we may receive or purchase from the business you represent.
Other Collection of Personal Information
In addition to the personal information collected above, we may also collect your personal information as follows:
- Social Media: If you choose to interact with us on social media, we may collect personal information about you from your social media account that you make public or share with us. We use personal information collected in connection with your social media account to communicate with you and better understand you and the business you represent.
- Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with you.
- Inquiry Information: If you choose to contact us, we will collect personal information in connection with your inquiry and correspondence with us. We may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
- Publicly Available Information: We may collect personal information from publicly available sources, such as government records or publicly available websites, to supplement the personal information identified above.
Other Uses of Personal Information
In addition to the uses of personal information identified above, we use the personal information we collect to:
- Facilitate our day-to-day business operations, such as negotiating the purchase of loans and other securities;
- Respond to your comments and questions and provide you support;
- Develop new services and offerings, and improve existing services and offerings;
- Aggregate information we receive from you and third parties to help understand your needs and provide you better service;
- Conduct research and analytics designed to understand the third parties we interact with and improve our services and offerings;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- Enforce and carry out contracts and agreements; and
- Comply with legal obligations.
Our Disclosure of Personal Information
We disclose personal information in the following ways:
- Within Redwood Trust: Redwood Trust is made up of many legal entities that are responsible for different aspects of our relationships with the individuals we interact with and the investment activities we engage in. To facilitate these interactions and activities, Redwood Trust entities disclose personal information to other Redwood Trust entities or our 5 Arch and CoreVest subsidiaries for purposes and uses that are consistent with this Privacy Notice. For example, we may transfer your contact information to the Redwood Trust entity designated for holding the loan we purchase from you or the business you represent.
- With Businesses You Represent: We may share personal information with businesses you represent in furtherance of the relationship between us and the business for which you are a representative.
- With Transaction Partners: We may share your personal information with other entities and third parties involved in a transaction we are undertaking with you and/or the business you represent. For example, we may share your contact information with due diligence providers or underwriters so they can connect with you to obtain the information needed to facilitate the transaction.
- With Data Analytics Providers: We share personal information with data analytics providers who analyze statistics and trends relating to the usage of and activity relating to our services. These data analytics providers produce reports and make suggestions for our business strategy based on the personal information and other information analyzed.
- With Marketing Partners: We coordinate and share personal information with our marketing partners, including marketing communication providers, in order to communicate with you about our services and offerings and market our services and offerings to you.
- With Investor Management Providers and Brokerage Firms: We share personal information about our prospective and actual investors with third parties we engage to assist in our investor management processes, including maintaining investor records, facilitating payment of dividends and preparing income tax returns. We also share personal information about our actual investors with the brokerage firms that represent them.
- With Vendor Management Providers: We share personal information with third parties we engage to assist in our vendor management processes, including maintaining vendor records and facilitating vendor payments on our behalf.
- With Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the use of personal information described in the Our Collection and Use of Personal Information section above, including website hosting, communications, information technology support, and fraud monitoring. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws and regulations or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of our agents,
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our customers, or any person; or
- as otherwise required by applicable law.
- Consent: We may disclose personal information about you to certain other third parties with your consent.
Children’s Personal Information
Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
Our websites and online services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Effective Date” at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by prominent posting on this website or 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 this Privacy Notice 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