LBA Ware Privacy Policy

Effective Date: June 19, 2020

Your privacy and the privacy of your information is extremely important to us. This Privacy Policy describes how L Brewer and Associates, d/b/a LBA Ware (also referred to as “us,” “our,” or “we” in this Privacy Policy), collects, processes, uses and stores information about you and how we protect the information. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. By using our websites (including our knowledge base and project management platform; individually and collectively, the “Web Site”) and our suite of products and services, you consent to the terms of our Privacy Policy and Acceptable Use Policy.

The Web Site and suite of products and services are referred to in this Privacy Policy, collectively, as Our Services. LBA Ware clients should also refer to their license agreement and other client agreements, which may state additional terms governing the use of our products and services.

1. The Information We Collect

We gather two types of information: (1) personally identifiable information that you supply voluntarily when you order Our Services or create a profile and (2) aggregate tracking and site usage information that we gather automatically as you access our Web Site. Your provision to us of any information through our Web Site, or through other sites that link to our Web Site, is deemed your agreement to this Privacy Policy. It is our policy to use the personally identifiable information we acquire at our Web Site for internal business uses only and to provide content, products, and services to you that you value and request. We do not authorize the use of your personal information by any third party. We operate and maintain a variety of online security measures to safeguard and keep your information private.

Personally-Identifiable Information You Provide to Us

Anyone can access our Web Site, but there are certain areas and services that require registration or provision of certain personal information if accessed, as described in greater detail below. If you choose to use such areas, we will ask for certain personally identifiable information, which may include name, mailing address, valid e-mail address and other personal information. We will also communicate with you in response to your inquiries, regarding any information or services you request, and to manage your account.  We will communicate with you by e-mail or other method as directed by you. If you decline to supply or maintain with us certain information while using our Web Site, please understand that you may not be able to use or participate in some or all of the features offered through the Web Site.

LBA Ware collects information from Website visitors and users of Our Services in a variety of manners, and also obtains information from third parties, including our clients’ borrowers and service providers, in the course of providing Our Services to clients. This information includes:

(i) Information You Provide for Sales and Product Demo Inquiries
When you request information through one of the contact forms on the LBA Ware website, we ask you to provide your name, email address, company name, telephone number, loan origination system (LOS), referral source, and other optional information you may provide.

(ii) Registration Information
When you register to use one of Our Services, we may collect certain information from you, including your name, title, email, company name, company address, telephone number, billing and invoicing contacts, and other information that we use to contact you or provide services to you.

(iii) Usage Information
Like most online services, we collect standard technical information when you use Our Services, including but not limited to unique device identifies, internet protocol (IP) addresses, browser types, internet service providers (ISPs), the number and duration of page visits and the number of clicks.

(iv) Cookies and Other Technologies
We collect certain information through the use of cookies (also called HTTP cookies or browser cookies) and other tracking technologies. Cookies are small files that your web browser places on your computer. We may use cookies and other tracking technologies to better understand how you interact with Our Services, to monitor usage by our users, web traffic, and to improve and personalize Our Services. Most Internet browsers automatically accept cookies. You can disable your browser from accepting cookies or instruct it to prompt you before accepting cookies from the websites you visit.

We may also use web beacons, which are transparent graphic images on a webpage or within the body of one of our marketing emails, to allow us to measure visitor actions and assess the effectiveness of Our Services or email marketing campaigns. For example, we use web beacons in our email marketing to track where a user clicks through a link in the email.

(v) Do Not Track
We track site users over time, but not across third party web sites and not to provide targeted advertising, and therefore do not respond to Do Not Track (DNT) signals. We do not track site users across third party websites. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your web browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. Third parties cannot collect any personally identifiable information from our Website or Our Services unless you provide it to them directly.

(vi) Borrower Information
In the course of delivering Our Services, we receive information about our clients’ borrowers, which is provided by our clients. Borrower information includes but is not limited to name, address, loan details, real estate values, and telephone number.

In some instances, we collect information directly from our clients’ borrowers, such as when we provide post-close surveys. We process this information on behalf of our clients. Our clients are responsible for providing notice and obtaining appropriate consents to collect data from their borrowers and to provide it to us as their service provider.

(vii) Transactional Information
LBA Ware may also create transactional records of each of the transactions or other events occurring through Our Services. This transactional information is generally collected for the purpose of calculating commissions, management, and reporting, to enable LBA Ware to provide Our Services, to enable the services provided by third parties, and to enable LBA Ware to comply with various legal obligations.

(viii) Messaging Services and Other Communications
LBA Ware enables users of certain services to communicate with each other and with LBA Ware through those services using messaging services like chat or email. We collect and process this information to enable our clients to communicate and collaborate.

(ix) Information from CompenSafe Users.
When you log in at the CompenSafe homepage, we collect and process your login ID and password to ascertain your identity and display the proper information to you.

(x) Information from LimeGear Users.
When you log in at the LimeGear homepage, we collect and process your login ID and password to ascertain your identity and display the proper information to you.

2. How We Use Your Information

We use the information we collect in a variety of ways to provide Our Services and to operate our business, including the following:

(i) To Provide Our Services
  • To operate, test, maintain, enhance and provide features of Our Services;
  • To provide services and information that you request; and
  • To provide support to clients, users, and site visitors.
(ii) To Improve, Analyze, and Personalize Our Services
  • To understand and analyze usage trends and preferences;
  • To monitor and analyze the effectiveness of Our Services;
  • To improve Our Services and develop new products, services, features, and functionality;
  • To personalize Our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use Our Services; and
  • To provide customized content and information.

(iii) To Contact You
We may use your email address or other information we collect to contact you for administrative purposes such as client support service or to send communications, including marketing or promotional communications relating to Our Services. Generally, you have the ability to opt out of receiving promotional communications as described below.

(iv) To Aggregate, De-identified Data
We aggregate and de-identify data collected through Our Services and use it for purposes such as creating and publishing reports about the use of our products and services, including users’ interests, usage patterns, and trends.

3. How We Share Information

We take your privacy extremely seriously, and we never sell, trade or otherwise transfer lists or email addresses to outside parties. This does not include when you consent to us doing so, as well as in the following circumstances:

(i) To Our Clients
Transactional information collected through Our Services may be available to and shared with client account administrators or other client account managers, and third parties for commission and management purposes. LBA Ware clients may use certain information they collect through Our Services for marketing or promotional communications.

(ii) To Our Service Providers
We work with third party service providers to provide services, application development, hosting, maintenance, operations, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information. These service providers are not permitted to use information we share that might identify you for any purpose other than to provide services to LBA Ware or to you.

(iii) In Aggregate, De-Identified Form
We may make certain aggregated, de-identified non-personal information available to third parties for various purposes, including:

  • For compliance with various reporting obligations;
  • For business or marketing purposes; or
  • To assist such parties in understanding our users’ interests, usage patterns, and trends.

(iv) Compliance with Laws and Law Enforcement and the Protection of Our Rights
We may disclose your information to a third party if,

  • We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request;
  • To enforce our agreements, policies and terms of service;
  • To protect the security or integrity of our Website or Our Services;
  • To protect the property, rights, and safety of LBA Ware, our users or the public from harm or illegal activities; or
  • To investigate and defend ourselves against any third-party claims or allegations.

(v) In Significant Business Transactions
Your information, including personal information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

4. Privacy Policies of Linked Sites

Our Website and Our Services may contain links to other sites. We are not responsible for the privacy practices or the content of such sites. If you have any questions about how these other sites use your information, please contact them directly.

5. Security

LBA Ware has physical, administrative and technical measures in place to maintain the security, confidentiality and integrity of the information gathered through the LBA Ware website and Our Services, and to help protect against the loss, misuse and alteration of such information. While we take reasonable steps to protect your personal information against security breaches and unauthorized access, no data transmission over the Internet can be guaranteed to be totally secure and therefore we cannot guarantee or warrant the security of any information you send to us.

6. International Visitors

Our Services are hosted in the United States (U.S.) and are intended for use in connection with the U.S. real estate and residential mortgage lending market. WE DO NOT COLLECT, ACCEPT, OR STORE PERSONAL INFORMATION REGARDING INDIVIDUALS LOCATED IN THE EUROPEAN UNION. If you are located in the European Union, you are not authorized to provide any personal information to us in any manner, whether through the Web Site or otherwise. If you choose to use them from other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the U.S. for storage and processing. By providing your information, you consent to any transfer and processing in accordance with this Privacy Policy.

7. How to Access and Update Your Information

You can access and update the information that you have provided to us as follows:

  • You may contact us at contact@lbaware.com and request to amend or delete your personal information collected by us through online, email or telephone sales contacts if you have not chosen to obtain services from LBA Ware.
  • If you have a CompenSafe account, you can review personal information, company information, and other data within the Employee/Branch/Company Details pages of CompenSafe. Any changes you request to make must go through your system administrator. We require that you keep your contact information current and accurate.
  • If you have a LimeGear account, you can review and make changes to certain personal information, company information, and other data within the Settings section of LimeGear. We require that you keep your contact information current and accurate.
  • You may opt-out of receiving marketing emails at any time by following the steps to “unsubscribe” described in the footer of our marketing emails. Your opt-out will become effective in 30 days or less.
  • If you are a client and choose to terminate your relationship with LBA Ware, you may be permitted under your Software as a Service (SaaS) agreement with LBA Ware to obtain a copy of your data. Please refer to the text of your SaaS agreement with LBA Ware for further information.

8. Children's Online Privacy Information

This Web Site is not intended for use by children under the age of 18. We do not knowingly collect information from children and minors. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children to never provide information on our Web Site without their permission.

9. Our Commitment to Data Security

We have put in place security hardware, software and software update and network scanning procedures designed to safeguard and secure the information under our control and follow generally accepted industry standards. We work with third party service providers and vendors that use encryption and authentication to maintain the confidentiality of your personal information. Although we will exercise high levels of care in providing secure transmission of information between your computer and our servers and in storing that information on our systems, no method of transmission over the Internet, or of electronic storage, is 100% secure. As such, we cannot ensure or otherwise guarantee the security of information transmitted to us over the Internet.

10. Changes to Our Privacy Policy

This Privacy Policy may be revised from time to time, so please review it frequently. We will post any changes to the Privacy Policy on the Web Site, but we have no other obligation to notify you of such changes. We indicate the date of the current version of this Privacy Policy below, so you know when it was last updated.

Any changes will affect all of the information we have previously collected from you, as well as the information we collect after such changes, and may include without limitation additional uses or disclosures of your information. If any of the changes represent a material change that expands our use of personal information, the changes will be posted in advance of taking effect. We may post a prompt on the home page of our site for users to review the new privacy policy but are not required to do so. If you object to the changes, please contact us as provided in this Privacy Policy and we will remove your information that we previously collected, to the extent consistent with this Privacy Policy and the terms of any other agreement between you and us. However, your subsequent provision of information to us through any of our Web Site is deemed your agreement to use of that information in accordance with the then-current privacy policy.