Effective Date: September 12, 2014
Regions Real Estate Capital Markets, a Delaware limited liability company (“Regions” or “us”) has adopted this online privacy policy (“Privacy Policy”) to inform you how we collect, use, disclose and protect the Personal Identifiable Information you provide us on our Commercial Real Estate (CRE) Term Lending Portal at snap.regions.com (“Site”). This Site will primarily be used by commercial real estate mortgage brokers, but potential borrowers will also use our Site from time to time. This Privacy Policy protects the Personal Identifiable Information about the brokers and potential borrowers who use our Site. References to “you” in this policy refers to the user of this Site, and, if such user is a broker, any borrowers for whom the broker submits Personal Identifiable Information to us through the Site. This Privacy Policy is hereby incorporated into the CRE Term Lending Portal User Agreement.
For purposes of this Privacy Policy, “Personal Identifiable Information” refers to information that can be used on its own or with other information to personally identify, contact or locate an individual.
We collect Personal Identifiable Information directly from you and automatically from you during your use of our Site. Information that we may collect about you or the borrower through online interaction includes information that you input, such as name, address, email address, other contact information or property information. We may also collect information that is sent to us automatically by your web browser. This information may include your IP address, the type of operating system and browser you use, the date and time of your visit and the pages you visit. We also gather information collected through cookies, tags and other technologies.
When submitting any information, including Personal Identifiable Information, about third parties to us, you warrant and represent that you have the authority to provide us with such information, and that the information you provide is accurate, complete and up-to-date.
During the registration process on our Site, we may collect Personal Identifiable Information. Additionally, to complete your loan application we may collect Personal Identifiable Information from you about you and/or potential borrowers including property information, loan information, borrower information, and principal information. We also collect information about you and/or your borrowers on our account registration forms, loan calculators and prerequisite term sheets. Some pages on our Site contain forms that require users to provide contact information (such as name and e-mail address), geographic information (such as ZIP code), and other similar information. This information is needed to identify you to our Site and to provide you with information that you have requested. In addition, we may use this information to provide you with effective customer service and provide information and advertising about products and services that you may be interested in. These forms and the information they request may change from time to time.
We may collect your IP address to help diagnose problems with our server and to administer our Site. The Site may also log IP addresses for systems administration purposes to track a user's session. This tracking also helps us evaluate your use of our Site so that we may improve our Site’s design and content to better serve you. If you log onto your account with us (as opposed to visiting our Site without logging on) your IP address is linked to personally identifiable information, but only while your logon session is active. This linkage is necessary at that time for security reasons.
Our Site uses Cookies to keep track of your login session. Once you log out, your session is terminated and the cookie is removed. If your browser is set to reject cookies, you will not be allowed to login to our Site until you change the setting to accept the cookie. Our Site does not process or respond to “do not track” requests at this time.
As permitted by law and as outlined in this Privacy Policy, we may disclose Personal Identifiable Information with affiliates and unaffiliated third parties that provide services to us or with whom we have contractual relationships in order to effectively and efficiently carry out your directions and service your account. Prior to disclosing any information, we ensure that there are contractual agreements with the third party prohibiting their use and disclosure of that information for any purpose other than to carry out the specific service, or that such third party is prohibited by law from further sharing your information.
We may disclose your Personal Identifiable Information with others as required by, or permitted by, law. This may include sharing your information with governmental entities, or third parties in response to subpoenas, court orders, other legal process, or as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us.
We may also disclose your Personal Identifiable Information if we determine, in our sole judgment, that the release of your information may protect the rights, property, or safety of you, us, or another person. We may also report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation.
If we become involved in a merger, acquisition, or any form of sale of some or all of our assets, your Personal Identifiable Information may be provided to the entities and advisors involved, who will each use such information in accordance with their own privacy policies.
Information you give us about other persons (such as information about someone you would like us to send marketing materials to) will be used only for the purpose for which you disclosed that information to us, as set forth in this Privacy Policy.
Regions is committed to protecting your Personal Identifiable Information. We have security policies and procedures reasonably designed to prevent unauthorized use or access to your information. Your information is available to employees who have a need to know such information for business purposes (e.g., to process or service transactions, and those fulfilling compliance, legal or audit functions). Our computer systems utilize password protection to prevent access by unauthorized personnel, and we employ other physical, electronic, and procedural safeguards to ensure the protection of your information in accordance with state and federal standards.
If you need assistance to access, update or correct your Personal Identifiable Information, please contact us at (844) 894-7627.
Our Site may contain links to other third party websites. When you click on one of these links, you will be leaving our Site and will no longer be subject to our Privacy Policy. We are not responsible for the information collection practices of the other websites that you visit and we encourage you to review their privacy policies before you provide them with any Personal Identifiable Information.
Our Site is not intended for children. We do not knowingly solicit Personal Identifiable Information from, or market online to, children.
We amend this Privacy Policy from time to time by posting an amended version of this policy to our Site. Please check our Site from time to time for amended versions of this Privacy Policy. Regions will revise the “Effective Date” stated at the top of this Privacy Policy at the time any material changes to the policy are made. Any updates to the Privacy Policy become effective when we post the updates to our Site. If at any time you do not agree to the terms of this Privacy Policy, you should cease any further use of the CRE Term Lending Portal.
If at any time you believe we have not adhered to this Privacy Policy, please notify us and we will use commercially reasonable efforts to promptly identify, diagnose and correct the problem. This is our sole obligation and your sole remedy for our breach of this Privacy Policy. You may reach us by mail at Legal Department, 4675 MacArthur Court, 15th Floor, Newport Beach, CA 92660.