Privacy and Security

Privacy

We respect your privacy. Tower Commercial Mortgage will never sell your personal information.

Your privacy is important to us. Tower Commercial Mortgage (“Tower”) respects and protects your personal information Tower understands the importance of keeping the personal information you provide to us private and secure. Tower considers the protection of sensitive information a foundation of client trust and a sound business practice. Tower has a comprehensive privacy policy and is committed to using technologies that provide a safe and secure computing experience as well as a long-term client relationship. Client information means personally identifiable information about a client or a client’s current or former relationship with Tower. This policy explains Tower’s collection, use, retention and security of client information. There is no need to opt-out of anything, we don’t sell or share any of your information for any reason other than to find a commercial mortgage for you.

Agreement to policy

By using a Site you consent to this Policy, including your consent to our use and disclosure of information about you in the manner described in this Policy.

Cookies Policy

A cookie is a small piece of text sent to your browser by a website you visit. Cookies play an important role. Without them, using the web would be a much more frustrating experience. It helps the website to remember information about your visit. That can make your next visit easier and the site more useful to you. Cookies can also be used to collect information about you to better tailor digital marketing and advertising activities.

Tower may use cookies to monitor visitor traffic to website pages and collect information about you. Personal information includes both Personally-Identifiable Information (PII) and Non-Personally Identifiable Information (Non-PII).  PII is information that identifies you as an individual – for example, your name, address, telephone number, e-mail address, credit card information, billing address and shipping information. Tower will not use cookies to collect any PII about you. Non-PII is aggregated information, demographic information, IP addresses, user behavior data from web interaction metrics tools and other information that does not reveal your specific identity. Only Non-PII may be collected by cookies anytime you access or use the Tower Commercial Mortgage website.

Non-PII will only be used to better target digital marketing, in advertising activities and in conjunction with Google Analytics to analyze Tower website traffic. Because Non-PII does not personally identify You, Tower reserves the right to use and disclose to third parties Non-PII for any purpose. Tower will not merge PII and Non-PII information that it may collect in conjuction with Google Analytics.

The Sources of Information

The Personally-Identifiable Information we collect about you comes primarily from the account application and online forms, interactions you have with Tower or other forms and materials you submit to Tower during the course of your relationship with us. In addition, depending on the products or services you require, Tower may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Tower’s website allows visitors to volunteer certain contact information and profile information; such as user name, e-mail address, profession, basic borrower financial information, commercial property information and so forth. The required information is clearly marked as such on appropriate web page forms or other forms provided to you by Tower for collecting your information. Personal, private information collected for a commercial mortgage or other commercial real estate financing from a potential client may be collected from a secured web page form, or by the phone, or secured email, overnight carrier or US mail.

In general, people may visit Tower’s website and access information while remaining anonymous and without revealing their identities to learn about our financial products and services. The only information we collect online from visitors to our website is from cookies or similar devices. Tower uses this information only to recognize you and hold information during your visit to the site. This general information allows us to monitor the use of our site so we can continually improve the design and functionality to better serve our clients.

Information We Have about You

Tower Commercial Mortgage collects various information about you in its effort to procure a commercial mortgage on your behalf. The information we typically collect about you may include:

Your name, address and other contact details;

Your age, occupation and marital status;

Personal and business financial information;

A head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required by laws and regulations addressing due diligence and related matters; and

A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

Your name and contact details;

Your role/position/title and area of responsibility; and

Certain identifying information (e.g. passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.

Of course, you are not required to supply any of the PII that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate and complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your PII.

Use and Sharing of Your Personal Information

Personally-Identifiable Information (PII) and Non-Personally Identifiable Information (Non-PII) you provide to Tower will be used in connection with facilitating our commercial mortgage services to you and distributing our newsletters. If you facilitate Tower’s commercial mortgage services, the information you provide will be used in the underwriting, processing, funding and servicing the loan for which you applied for to interested lenders. Tower does not share any information about you or your company to unaffiliated third parties, except as necessary to underwrite, process, fund and service your loan and as permitted by law. Tower does not share, distribute, sell or otherwise disseminate any information about you or your company, except as detailed in this Tower Commercial Mortgage Privacy Policy. Tower does not share client information about our clients with unaffiliated third parties for use in marketing their products and/or services.

Disclosing of Your Personal Information to Third Parties

Tower does not disclose your any of your personal information (both PII and Non-PII) to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies such as commercial mortgage lenders or to procure financing on your behalf, including those that provide professional, legal or accounting advice to Tower. Non-affiliated companies that assist Tower in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Tower dictates.

Under limited circumstances, your personal information (PII) may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.

 

Information security

E-mail Fraud

E-mail can be used for sending scams such as a false offer from a company or an alert to a false computer virus. These e-mails are often forwarded with good intention by friends, adding an erroneous level of legitimacy. If you receive an e-mail that you think could be a scam, do not forward it and delete it immediately. If you receive an e-mail warning that a new computer virus is circulating, check the Website of any one of the well-known anti-virus software companies for validation.

Emails such as these are most likely from criminals who send thousands of emails at a time to random addresses. These criminals are trying to entice the recipient to visit a phony website and provide personal and confidential information, such as online IDs and passcodes, or Social Security numbers and account numbers. Although the site may look like the original, it is not – which is why this practice is known as “spoofing.”

To report a suspicious email that uses Tower’s name, you can forward it to email abuse

Legal Information

Although we do everything within our power to protect the privacy of the information provided by the users of our site, we may need to disclose personal information when required by law or where we have a good-faith belief that such disclosure is necessary to comply with a current judicial proceeding, a court order, legal process served on our website, or in order to investigate, prevent, or take action regarding illegal activity. For example, we may disclose personal information to law enforcement, other government officials, or third parties in response to criminal or civil subpoenas.

Looking out for children

We do not knowingly market to or solicit information from children under 13. We recognize that protecting children’s identities and privacy online is important and that the responsibility to do so rests with both the online industry and with parents. While Tower works to protect your personal information, you also have responsibility. Learn how to protect your information.

Internet safety for children. The Internet is a public network. Children’s access to the Internet can allow them to visit inappropriate Web sites and be exposed to unwanted risks. COPPA, the Children’s Online Privacy Protection Act, protects children under the age of 13 from the online collection of personal information. Learn more about COPPA on the Federal Trade Commission’s Web site. Parents can be proactive by installing filtering software that gives them more control over their family’s Internet experience.

Cyber ethics for children. Cyber ethics is the practice of being a good citizen on the Internet superhighway. Kids should understand the rules of the road, too. Learn more by visiting the U.S. Department of Justice’s kids and youth Web site.

Changes to the Tower Commercial Mortgage Privacy Policy

We may make changes to this Privacy Policy. When we make a change, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. All changes will become effective when posted unless indicated otherwise.

Tower Commercial Mortgage welcomes comments and questions on this policy

We are dedicated to protecting your personal information. Any comments or questions regarding our privacy practices are welcome. Please email us with your comments. You do not have to contact us to benefit from Tower’s privacy protections; they apply automatically to all of our current and prospective clients.

Former Clients

If you are a former client these policies also apply to you; we treat your information with the same care as we do information about current clients.

 

Last updated: March 7, 2018