California Consumer Privacy Act Applicant Notice and Policy

CrossCountry collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device. CrossCountry may collect the following categories of personal information from consumers. Categories of personal information collected in the last twelve (12) months are indicated by the term ‘YES’ in the ‘Collected’ column: 

CrossCountry has disclosed each of these categories of consumer personal information for business purposes to the following categories of third parties: 

CrossCountry mortgage will only retain personal information for the length of time needed to fulfill the purpose for which it was collected. 

CrossCountry obtains the categories of personal information listed above from the following categories of sources: 

• Information you provided directly to us. 

• Directly and indirectly from activity on our website. For example, a consumer’s IP address, kind of web browser and computer used, and locality including the state or country from which the consumer accessed the site. 

• Collected via CrossCountry’s website technologies. 

• Online job platforms. 

• Social Networks. 

• Public record sources including Federal, state or local government. 

CrossCountry may collect or disclose consumer personal information for one or more of the following business purposes: 

• To manage and administer employee services, such as employee benefits, processing payroll. To conduct employee-related analytics; conduct performance reviews; and establish, maintain, and terminate employees’ relationships with CrossCountry Mortgage. 

• To evaluate our current recruiting processes. 

• To evaluate eligibility for initial and continued employment, including processing and verifying information provided pursuant to a job application, and performing background checks of new applicants and existing employees. 

• To conduct training, take disciplinary action, and address work-related incidents. 

• To document your receipt and acceptance of agreements presented to you. 

• To comply with recordkeeping obligations and policies. 

• To maintain internal employee directories and to facilitate work-related communications with employees. 

• To respond to employment-related incidents and process work-related benefit claims. 

• As necessary or appropriate to protect the rights, property or safety of CrossCountry and our consumers or others. For example, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. 

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. 

• To establish or defend legal claims and allegations. 

• To verify an employee’s compliance with employment-related training or certification requirements. 

• To seek advice from attorneys, auditors and other professional advisors. 

• As described to consumers in any notice provided at or before the time of collection of personal information, or as otherwise set forth in the CCPA. 

• To evaluate or conduct a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CrossCountry is among the assets transferred, or personal information held by CrossCountry is used to assess assets or personal information held by another. 

Note: CrossCountry will not collect additional categories of personal information or use the collected personal information for materially different, unrelated, or incompatible purposes without providing notice to consumers. 

CrossCountry has disclosed the following categories of personal information to third parties for a business purpose in the previous twelve (12) months: 

• A. Identifiers; 

• B. Personal information categories; 

• C. Protected classification characteristics; 

• F. Internet or similar network activity; 

• G. Geolocation data; 

• H. Sensory data; 

• I. Professional or employment related information 

• J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)); and, 
• K. Inferences drawn from other personal information. 

CrossCountry has disclosed each of these categories of consumer personal information for business purposes to the following categories of third parties: 

CrossCountry has not shared personal information subject to the CCPA in the last twelve (12) months. 

CrossCountry has sold the following categories of personal information to third parties in the previous twelve (12) months:

CrossCountry may sell consumer personal information to third parties for one or more of the following commercial purposes: 

• To market our products and services to California consumers. 

CrossCountry does not use or disclose sensitive personal information other than: 

• To provide the products and services requested by you. 

• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information. 

• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions. 

• To ensure the physical safety of natural persons. 

• To perform services on behalf of CrossCountry. 

• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer. 

CrossCountry does not knowingly collect, sell, share, or disclose the personal information of a person less than 16 years of age. 

The CCPA provides California residents with specific rights regarding their personal information. This section describes consumers’ CCPA rights and explains how to exercise those rights.

California consumers have the right to request that CrossCountry disclose certain information about the collection and use of personal. Before CrossCountry discloses information, it will ask for information to verify the requestors identity.  Once CrossCountry receives and confirms a verifiable consumer request, we will disclose the following: 

• The categories of personal information CrossCountry collected about the consumer. 

• The business or commercial purpose for which CrossCountry collected, sold, or shared the information; 

• The categories of third parties to whom CrossCountry disclosed the category of personal information for a business purpose; 

• The categories of personal information that CrossCountry sold or shared and the categories of third parties to whom the personal information was sold or shared. 

• The categories of personal information of the consumer that CrossCountry disclosed for a business purpose and the categories of persons to whom the personal information disclosed. 

Additionally, if a consumer requests specific pieces of personal information collected by CrossCountry and provides the requested identifying information, CrossCountry will disclose the specific pieces of personal information to the requestor. 

Note: CrossCountry may not disclose the requested information if it cannot verify a requestor’s identity. CrossCountry may not disclose certain information covered by one or more exemptions from the CCPA, as discussed earlier in this Disclosure. Under no circumstances will CrossCountry disclose a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers. 

Deletion Request Rights 

Consumers may request the deletion of personal information collected and retained by CrossCountry. Upon receipt and confirmation of a verifiable consumer request, CrossCountry will delete (and/or direct CrossCountry service providers to delete) consumer personal information from applicable records, unless an exception applies.  If CrossCountry denies a consumer deletion request, it will inform the consumer and explain the basis for the denial. 

Correction Request Rights 

Consumers may request the correction of inaccurate personal information collected and retained by CrossCountry. Upon receipt and confirmation of a verifiable consumer request and supporting documentation (if necessary), CrossCountry will correct (and/or direct CrossCountry service providers to correct) the inaccurate consumer personal information in all applicable records, unless an exception applies.  CrossCountry will inform the consumer whether it has complied with a consumer correction request. A consumer’s request to correct may be denied if CrossCountry determines that the contested information maintained by CrossCountry is more likely than not accurate based on the totality of relevant circumstances. If CrossCountry denies a consumer correction request, it will inform the consumer and explain the basis for the denial. 

Right to Opt-Out of Selling or Sharing 

CrossCountry does not share California consumer personal information as defined in the CCPA. 

Consumers may opt-out of the sale of their personal information collected by CrossCountry. Upon receipt of a consumer request CrossCountry will stop selling the consumer’s non-exempt personal information to third parties as soon as feasibly possible, but no later than 15 business days from the date the CrossCountry receives the request. CrossCountry will also notify all third parties to whom CrossCountry has sold the consumer’s personal information that the consumer has made a request to opt-out of the sale of their personal information and will direct them to comply with the consumer’s request and forward the request to any other person to whom the third party has made the personal information available during that time period. 

Non-Discrimination Rights 

CrossCountry will not discriminate against any California resident, including consumers, employees, applicants, or independent contractors, for exercising any CCPA rights. Except to the extent permitted by the CCPA, CrossCountry will not: 

• Deny you goods or services; 

• Charge different prices or rates for goods or services based upon provision of personal information, including through granting discounts or other benefits, or imposing penalties; 

• Provide different levels or quality of goods or services; or, 

• Suggest that a consumer may receive a different price or rate for goods or services or a different level or quality of goods or services. 

How to Exercise Rights 

A consumer may exercise the rights described above by submitting a request to CrossCountry by either: 

• Calling us at 844-940-CCPA (2272) 

• Completing the online webform – California Privacy Request or 

• For Requests to Opt-Out of the Sale of Personal Information – click on the “Do Not Sell or Share My Personal Information” button found in the banner at the bottom of this webpage. 

A consumer must describe the request with enough detail so that CrossCountry may properly understand, evaluate, and respond to the request.  A consumer may request to know and access personal information no more than twice within any 12-month period. 

Other than for a request to opt-out of the sale of personal information, CrossCountry will respond only to requests that are verifiable consumer requests.  As a result, CrossCountry will seek to verify a consumer’s identity upon receipt of any request. CrossCountry will ask information from the requestor that enables identification, such as the consumer’s email address or the last four digits of the consumer’s social security number.  CrossCountry also may use a third-party verification provider to verify a consumer’s identity.  

Correction Request: As part of a request to correct inaccurate information that CrossCountry maintains about a consumer, the consumer submitting the request must provide any documentation that rebuts the accuracy of the contested information maintained by CrossCountry. 

Authorized Agents: An authorized person may submit a CCPA request on behalf of a consumer using the telephone number or online webform shown above. An authorized agent will be required to provide their contact information, the verification information of the consumer on whose behalf they are making the CCPA request, any documentary evidence as part of a correction request, and to submit evidence of authorization to act on behalf of the consumer in the form of either: 

• A document signed by the consumer giving the authorized agent permission to act on behalf of the consumer (CCM may also contact the consumer directly to verify their identity and that authorization has been given) 

• A power of attorney pursuant to Probate Code sections 4121 to 4130 

CrossCountry cannot respond to a request or provide a consumer with personal information if it cannot verify the identity of the consumer, the authority of a third party to make the request, and/or confirm the requested personal information relates to the consumer.  Making a request does not require the creation of an account with CrossCountry.  CrossCountry will only use personal information provided in a request to verify the requestor’s identity or authority to make the request. 

Response Timing and Format

CrossCountry strives to respond to each verifiable consumer request within 45 days of its receipt.  If CrossCountry requires more time, it will inform the requestor of the reason and extension period in writing.  If the requestor has a pre-existing account with CrossCountry, CrossCountry may deliver its written response by means of that account.  If the requestor does not have a pre-existing account, CrossCountry may deliver its written response either by mail or electronically.  For request to know and access personal information requests, CrossCountry will select a format to provide a consumer’s personal information that is readily useable and allows the consumer to transmit the information from one entity to another entity without hindrance. 

CrossCountry does not charge a fee to process or respond to a verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded.  If CrossCountry determines a request warrants a fee, CrossCountry will inform the consumer of the decision and provide a cost estimate before completing the request. 

Request to Opt-Out of Selling 

CrossCountry will stop selling the consumer’s personal information and will direct any applicable third parties to comply with the consumer’s request and forward the request on to any additional applicable third parties as soon as feasible but no later than 15 business days from the date the CrossCountry receives the request. 

Changes to This Disclosure

CrossCountry reserves the right to amend this Disclosure at its discretion and at any time. When CrossCountry makes changes to this Disclosure, it will notify consumers by posting a link to the updated Disclosure to its website homepage.  Consumers should check back periodically for any updates. 

How to Contact Us

For questions or comments about this Disclosure, our Privacy Statement, the ways in CrossCountry collects and uses consumer personal information, consumer choices and rights regarding such use, or exercising rights under California law, please contact CrossCountry at: 

Phone: 844-940-CCPA (2272)
US Mail:
CrossCountry Mortgage, LLC
Attn: Marketing Compliance Manager
2160 Superior Avenue
Cleveland, OH 44114 

Or please contact CrossCountry by sending an email to: [email protected]  

This policy was last updated 06/28/2024.